Biscuit is hard baked product like a small flat cake which in North America may be called a "cookie" or "cracker". The term biscuit also applies to sandwich type biscuits, where a layer of 'cream' or icing is sandwiched between two biscuits. It should be noted that it has become increasingly common in the UK for "cookie" to be used to differentiate between the softer, more chewy "cookie" and the harder, more brittle "biscuit." In this respect the British usage of the word biscuit was defined in the defense of a tax judgment found in favour of McVitie's.