Emil ALEXIEV

Belgrade - 24 October 2013 1

Emil ALEXIEV

Practical experience of qualified entities Practical experience of qualified entities

in bringing actions for injunctionin bringing actions for injunction

Cease and desist order (action for injunction)Cease and desist order (action for injunction)

Objective of the action: to defend the collective interests of all consumers;

Plaintiffs: public authorities for consumer protection, consumer organizations, other organizations recognized under national law as “qualified entities”;

The aim of the action is to prevent or to order to cease a practice, the use of unfair contract terms, the use of unfair commercial practice, of misleading advertising. The injunctive action does not have a “reparative effect”; it aims at preventing infringements of consumer legislation – in the future;

Remedies available: cease and desist order to stop an infringement of the legislation;

The object of the actions harmonized by Directive 2009/22/EC is to obtain an order of the court, or of the administrative authority requiring the cessation or prohibition of acts contrary to consumer legislation.

Technical Assistance to Ukraine 2

Cease and desist order (action for injunction)Cease and desist order (action for injunction) Cessation refers to stopping acts actually violating the law, while

prohibition refers to acts that are still not violating the law but are on the edge of doing so (for instance, a misleading advertising about to be published), and also to prevent for the future the repetition of similar acts violating the law that are ordered to be stopped;

Thus, an injunction is an order of the court, or of the administrative authority to not do something;

The action provided for by Directive 2009/22/EC on injunctions for the protection of consumers ‘interests is an action for the protection of collective interests of consumers;

Protecting collective interests of consumers, the injunction action plays a preventive role, seeking to avoid the infringement of individual interests of consumers;

The collective interests of consumers are that consumer legislation shall not be infringed in order to prevent any violation of their individual interests. For instance, consumers have the collective interest to prevent the use of unfair contract terms in standard contracts, in order to eliminate the possibility that one of them concludes a standard contract including an unfair term.


Practical experience of qualified entities in bringingPractical experience of qualified entities in bringing actions for injunction actions for injunction

Actions for injunction – Why?• benefit for consumers generally: injunction against unfair

terms and against unfair commercial practices;• benefit for individual consumer: injunction against unfair term

used in consumer lawsuit;• markets enhanced respect for consumer laws: deterrent

against cross-border and national consumer scams


Practical experience of qualified entities in bringing Practical experience of qualified entities in bringing actions for injunctionactions for injunction

Directive 2009/22/EC on the protection of consumers’ collective interests;

Different models of injunctions: cross-border injunction (Directive’s model); cross-border injunction proceedings (from home base); domestic injunction proceedings;

Qualified entities notified to the EU Commission; Criteria for recognition as a qualified entity Practical experience of enforcing Directive 2009/22/by qualified

entities Difficulties related to the enforcement of Directive 2009/22/EC;


Practical experience of qualified entities in bringing Practical experience of qualified entities in bringing actions for injunctionactions for injunction

Qualified entity sues abroad for cross-border infringement: The Directive’s model. Rarely used and recently not at all. These cases are regulated at EU level by the Injunctions Directive. Up to now, there was a very limited use of the Directive made to counter cross border infringements during the first 10 years of application;

According to the Commission's information, only the UK's Office of Fair Trading (OFT, public authority in charge of consumer protection) has used the mechanism in several cases.

Qualified entity sues at home for cross-border infringement: National law, helped by EU-PIL. Used in a number of Member States.These cases are to a considerable extent regulated by EU law as far as private international law and international law on civil procedure are concerned. In terms of providing benefits for consumers in the internal market;

Qualified entity sues at home for domestic infringement: National law. Commonly used in nearly all Member States. These cases are subject to national law;


Cross-border injunctions (Directive’s model)Cross-border injunctions (Directive’s model)

The Directive was drafted to permit qualified entities of Member State A to go after business operators in Member State B if the latter, in trading with consumers in Member State A, were breaching consumer laws. In order to make this possible, qualified entities were vested with legal standing in foreign courts;

The court in Member State B, seized with the request to issue a cease-and-desist order against the trader established within its jurisdiction, would hear and decide the case without questioning the legal standing of the qualified entity of Member State A;

The qualified entity could sue in a foreign court in this way, at least in theory. Pursuing intra-Community infringements, it would be the qualified entity who cross the border;

the Directive’s design of ‘cross-border cases’ is only one of two possible forms of injunction proceedings with an intra-Community dimension. It is also the one that is rarely used.


Cross-border injunctions proceedings (from home base)Cross-border injunctions proceedings (from home base)

• The second, more common form of cross-border case arises from the same scenario of trader from Member State B into Member State A;

• Different from what the drafters of the Directive had in mind, however, a lawsuit is brought by a qualified entity in Member State A before a court in Member State A;

• The trader, although established abroad, is sued in the country to which he was directing his commercial activity;

• Operating this way has the advantage for a qualified entity of filing a case in its own familiar jurisdiction that applies the procedural law it probably knows best;

• If the applicable law is then also the law of Member State A (here, the principle of Article 6 and recital 21 of Rome II (Regulation (EC) No. 864/2007 on the law applicable to non-contractual obligations – Rome II Regulation) is of crucial importance;

• Country where the market is (most) affected. Recital 21 of the preamble to Regulation 864/2007 (‘Rome II’), explaining Article 6: “In matters of unfair competition, the conflict-of-law rule should protect competitors, consumers and the general public and ensure that the market economy functions properly.

• Pursuing intra-Community infringements, qualified entity stay at home and it is the trader-defendant who crosses the border.Belgrade - 24 October 2013 8

Domestic injunctions proceedings Domestic injunctions proceedings

A third variety of injunction proceedings are purely domestic.

For these, the law derived from the Directive is influential, in particular in those countries that did not include in their legal systems of injunctions proceedings in their legal systems before the transposition of the Directive;

Whilst injunctions are still used rarely for cross-border infringements, qualified entities of several Member States use successfully consumer domestic injunctions for national infringements, often in order to have misleading advertising stopped or to annul an unfair term in a contract.


Qualified bodies notified to the EU Commission (1)Qualified bodies notified to the EU Commission (1)

Austria has notified 8 qualified entities to the EU Commission. The list is composed by the Federal Ministry of Economy, Family and Youth;

Belgium has notified 2 qualified entities (Test Achat and one more consumer organization);

Bulgaria has notified 8 qualified organizations (State body +7 consumer organizations). Legal standing to bring injunctive relief actions is granted both to non-governmental consumer organisations and to the State body in charge of consumer protection. Business organisations are not authorised to initiate actions for injunction in court to cease national or cross-border infringements of consumer protection legislation.

Czech Republic has notified 4 consumer organizations as qualified entities;

Denmark has notified 2 qualified entities: The Consumer Ombudsman and the Danish Medicine Agency (public bodies for consumer protection)

France has notified 18 consumer organizations as qualified entities. Recently it has notified also the Direction general de la Concurrence, de la Consommation et de la repression des fraudes;

Germany has notified 76 qualified entities to the EU Commission; Ireland has notified 1 qualified entity, (the National Consumer

Agency);Belgrade - 24 October 2013 10

Qualified bodies notified to the EU Commission (2)Qualified bodies notified to the EU Commission (2) Greece has notified 71 qualified entities (consumer organizations and

chambers of commerce); Italy has notified 17 qualified entities (all of them consumer

organizations); Cyprus has notified 3 qualified entities (2 consumer organizations and

the Competition and Consumer Protection Service with the ministry of Commerce, Industry and Tourism;

Latvia has notified 1 qualified entity , the Consumer Rights Protection Centre, the State body in charge of consumer affairs;

Lithuania has notified 1 qualified entity , the National Service for the Protection of Consumer Rights;

Luxembourg has notified 2 qualified entities to the EU Commission (2 consumer organizations);

Hungary has notified 8 qualified entities (8 consumer organizations); Malta has notified 4 qualified entities. The following State bodies have

been notified to the EU Commission: Consumer and Competition Division; Malta Tourism Authority; Broadcasting Authority; Medicines Authority


Qualified bodies notified to the EU Commission Qualified bodies notified to the EU Commission (3)(3) Netherlands has notified 1 qualified entity. The “Consumentenbond” in the only

qualified entity notified to the EU Commission; Poland has notified 4 qualified entities among them the Consumer Ombudsman and

the Insurance Ombudsman; Portugal has notified 4 consumer organizations as qualified entities. However, only 2

of them are considered to having the capabilities of bringing actions for cross-border infringements:

DECO (Portuguese Association for the Defense of Consumers); Consumer Association of Portugal.

Slovenia has notified 14 qualified entities (12 consumer organizations, 1 chamber of commerce and 1 chamber of crafts);

Finland has notified 9 qualified entities; Sweden has notified 1 qualified entity – the Consumer Ombudsman. None of the

consumer organisations in Sweden has been included in the list as qualified entities for injunctions before foreign courts;

The Ombudsman in Sweden is a public official of high reputation who is also the head of the Swedish Consumer Agency. In cases of greater significance, or where voluntary compliance cannot be achieved, the Ombudsman can file an action for injunction before the specialised Market Court . Depending on the violation, the Consumer Ombudsman can seek an injunction to cease an infringement or a positive injunction, i.e. a court decision ordering information disclosure. None of the consumer organisations in Sweden has been notified as qualified entity


Qualified bodies notified to the EU Commission Qualified bodies notified to the EU Commission (4)(4)

Romania has notified 1 qualified entity (consumer protection association);

Slovakia has notified 11 qualified entities (consumer organizations); Spain has notified 28 qualified gentilities (public authorities for

consumer protection and consumer organizations); UK : The following bodies in UK were awarded the status of qualified

entities. These are the general enforcer: Office of Fair Trading and the following sectoral regulators:- The Information Commissioner’s office (data protection and freedom of information);- The Civil Aviation Authority;- The Office of Gas and Electricity Markets;- The Office for the Regulation of Electricity and Gas (Northern Ireland);- The Office of Communications;- The Office of Water Services;- The Office of Rail Regulation;- 240 weights and measures authorities in UK;- The Department of Enterprise, Trade and Investment in Northern Ireland. Belgrade - 24 October 2013 13

Qualified entities - experience of BulgariaQualified entities - experience of Bulgaria

In Bulgaria, the minister of Economy and Energy draws up a list of the qualified entities (organizations) which have legal interest to bring actions for cessation or for prohibition of commercial practices which violate the collective interests of consumers. The list is drawn up on the basis of criteria set forth with a regulation of the minister. The regulation contains the following criteria for recognition of the “qualified entities”:

to aim at the protection of the collective interests of consumers; to be registered at the Ministry of Justice as not-for-profit

organizations called upon to serve the public good; have carried out activities in favour of consumers during the last

two years; are economically independent from producers, importers, traders

and suppliers; are independent form political parties; does not disseminate in any form whatsoever in their publications

advertising messages or communications which might hamper the independence of the organization.

The administrative authority in charge for consumer protection in Bulgaria is

automatically put on the list of “qualified entities”;The minister of Economy and Energy has to provide to the EuropeanCommission the list of qualified organizations as well as their subject

ofactivity and legal organization.Belgrade - 24 October 2013 14

Qualified entities - experience of Slovakia and GreeceQualified entities - experience of Slovakia and Greece

Slovakia In Slovak Republic, the consumer protection organizations are

empowered to bring an action to court to protect the collective interests of consumers;

According to the Act on Consumer Protection, every consumer shall be entitled to associate themselves with other consumers in consumer protection organization which are entitled to act in court to stop infringements of consumer legislation;

Greece In Greece, consumer organizations which have at least 500 active

members and which have been entered in the register of consumer organizations for at least two years may bring a cease and desist action to protect the collective interests of consumers, i.e. to stop the illegal behavior of suppliers;

Additionally, chambers of commerce, industry, crafts and professions can bring collective actions against the suppliers.


Qualified entities - experience of UKQualified entities - experience of UK

The UK traditionally relies on public enforcement of consumer law. All qualified entities are public authorities; General enforcers are the Office of Fair Trading (OFT) and the Local Trading Standards. The OFT is given the role of principal enforcer with national responsibilities while the trading standards departments are active locally. Sectoral regulators have national responsibilities within their designated scope of activity. They include various regulatory bodies;The OFT is the most active of enforcement bodies. It is also one of the few bodies with first-hand experience in commencing and pursuing cross-border infringement procedures; Consumer organisations gained the power to go to court as a result of the transposition of Directive 98/27/EC on actions for injunction. However, up to know consumer organisations do not have initiated any actions for injunction relief.


Qualified entities - experience of UK (2)Qualified entities - experience of UK (2)bringing cross-border infringements before foreign courts: The OFT is one of the few qualified entities in Europe to have made use of the

availability of cross-border injunctions. It has initiated the following proceedings in relation to cross-border infringements

before the Commission’s first application report on the Injunctions Directive was published at the end of 2008:

2002 – OFT action against Royal Consulting, a Dutch company which was sending unsolicited first aid kits to UK residents accompanied by demands for payment;

2004 – OFT action against Belgian company Duchesne SA trading in Belgium. This Belgian company had sent UK consumers unsolicited sales catalogues saying that they had won a prize. To receive the prize, consumers had to order an article from the catalogue. Consumers ordered an article from the catalogue but did not receive the promised prize. The OFT therefore took the Belgian company in question to court in Belgium on the basis that the information given to UK consumers was misleading and had encouraged them to buy products from the catalogue. The Belgian court of first instance issued an injunction against the practice. This ruling was confirmed on appeal;

2005 – OFT action against Fitanova BV, a Dutch company selling health-related products and sending misleading mailings to UK residents;

2006 – OFT action against the company Best Sales B.V. before the Dutch courts: Following 300 complaints from UK consumers the OFT brought an action against the company Best Sales B.V. before the Dutch courts. A Dutch mail order company sent unsolicited mail to UK consumers giving them the impression that they had won a prize. The mail stated that in order to receive a more valuable prize or to receive this prize more rapidly, the consumers needed to order household articles from the catalogue attached to the mail. The Dutch courts considered in its ruling that the advertising was misleading and ordered the company to stop sending these mails.


Qualified entities - experience of UK (3)Qualified entities - experience of UK (3)

bringing cross-border infringements before domestic courts: No cross-border cases have been filed before domestic courts (action for

injunction before a UK Court against traders established in another Member States;

Domestic injunctions:Domestic injunctions: Injunctive relief sought in the domestic context (Injunction Orders) are Injunctive relief sought in the domestic context (Injunction Orders) are

commonly used;commonly used; UK enforcement bodies, mainly the general enforcers, are very active in UK enforcement bodies, mainly the general enforcers, are very active in

pursuing cases against infringements of consumer laws;pursuing cases against infringements of consumer laws;

Application of the Directive by qualified entities in UK:Application of the Directive by qualified entities in UK:Injunctions per subject matter: A large number of injunction proceedings concern unfair commercial practices,

(scams distributed by mail order and fraudulent prize draws ), misleading advertising, unfair contract terms, distance selling, timeshare and consumer credit

Injunctions per sector of the economy (business sectors affected):The sectors in which domestic or cross-border injunctions are mostly used are: Timeshare and other holiday products, cross-border lottery scams, false prize

draws and consumer credit.


Application of Directive 2009/22/EC by qualified entities in Application of Directive 2009/22/EC by qualified entities in BulgariaBulgaria

Injunctions per subject matter: A large number of injunction proceedings concern unfair

commercial practices and unfair contract terms; Most of injunction relief action relate to unfair contract terms,

mainly in financial services, utilities and telecommunications. Distance selling: 28 injunctive redress actions filed for the

period 2007-2010; Advertising: injunctive redress actions were brought to

prohibit violation of tobacco advertising and advertising of consumer credit;

A large number of injunction cases on first sight appear not to be covered by the scope of the Directive, like telecom, energy or insurances. In fact, most of these injunction cases are either based on the unfair contract terms directive or on the UCP Directive


Application of Directive 2009/22/EC by qualified entities in Application of Directive 2009/22/EC by qualified entities in BulgariaBulgaria

Injunctions per sector of the economy (business sectors affected):

Bulgarian ‘qualified entities’ have not experienced up to now any cross border actions for injunction;

Actions for injunction affect all business sectors. However, the focus of injunctions lies on financial services, insurances, telecommunication, distance selling, package travel and scams

The sectors in which domestic injunctions are mostly used are: retail trade, direct selling, non-food consumer goods, telecommunications, and energy (electricity and central heating supply;

Most of injunction relief action relate to unfair contract terms, mainly in financial services, utilities and telecommunications.

The implementation of the directive has had positive effects in the sense of enhancing competition on the following markets:

the market of electricity supply, where injunctive actions were filed against all biggest companies for electricity supply;

the market of direct selling (teleshopping), where 28 injunctive actions were filed against traders selling at distance.

Generally, scam cases account for a big percentage of actions for injunction brought by qualified entities;


Practical experience of enforcing Directive 2009/22/EC by Practical experience of enforcing Directive 2009/22/EC by qualified entities in Bulgaria (1)qualified entities in Bulgaria (1)

Action for injunction to stop and prohibit the advertising of mortgage credit by a bank which indicated an interest rate without indicating the APR of charge of the credit. In this case the court had to assess whether there has been violation of the provisions of Article 15 (1) of the Law on Consumer Credit

Subject matter of the claim: advertising of consumer creditThe following claims were submitted to the court: - to stop the advertising of the tobacco product above; - to prohibit the future advertising above, in violation of the provision of

Article 15 of the Law on Consumer Credit; - to require the trader to make public the decision of the court the court of first instance dismissed the claim; the court of appeal suspended and prohibited the advertising above

which was in violation of the provisions of the Law on Consumer Credit



Action for injunction against the company for electricity supply to declare as unfair several clauses, included in the general contract terms for supply and sale of electricity.

Subject matter of the claim: unfair contract termsAdditional subject matter of the claim: - to order the cessation of the use of the above-mentioned

clause; - to order the trader to withdraw the clause from the general

terms of the contract for the supply of electricity; - to require the trader to make public the decision of the

court at his cost.

The court had to assess the legitimacy of some stipulations contained in the contract for the supply of electricity;



Concretely, the Court was of the opinion that the following terms were contrary to Article 143 (1) of the Law on Consumer Protection:The clause allowing the supplier to refuse the supply of electricity provided that the consumer does not provide all documents required by the supplier. However, the terms of the contract do not specify what kind of ‘documents’ the consumer must provide to the supplier. Therefore, the court decided that a clause allowing the trader to interpret exclusively the terms of the contract, namely to interpret the meaning of the word ‘document’ is giving him the right to refuse the conclusion of a contract;The clause limiting the responsibility of the supplier of electricity to 90 days after the expiry of the deadline that has not been respected by the supplier, while the legislation provides for 5 years time period for the consumer for claiming compensation from the supplier;



The clause limiting to 90 days the responsibility of the supplier of electricity, in case of interruption of the supply.

The clause limiting to 90 days the time period for the consumer to claim for a compensation from the supplier for non respect of the deadlines under the contract, while the legislation provides for 3 years time period for the consumer for claiming compensation from the trader for breach of the contract.

The court declared the above-mentioned clauses, contained in the general conditions of the contract of the electricity supplier as unfair.



Subject matter of the claim: unfair contract termsThe authority for consumer protection brought an action under Article 186(3) of the Law on Consumer Protection against the insurance company to stop the use of an unfair term and withdraw from its general conditions of the contract the clause which entitles the trader to terminate the insurance contract at any time without giving notice to the consumer and without allowing the same right for the consumer.



Subject matter of the claim: unfair contract termsThe following claims were submitted to the court:- to proclaim the above-mentioned terms as unfair;- to order the cessation of the use of the above-mentioned clauses;- to order the trader to withdraw the clauses above from the general terms of the contract for the provision of mobile telephone services;- to order the trader to make public the decision of the court. Action for injunction to declare as unfair, clauses, included in the general conditions of the contract for the provision of mobile telephone services of a company in the sector of telecommunications.; In this case the Court had to assess the legitimacy of a number of stipulations in terms of contract for mobile telephone services with regard to the provision of Article 143 (1) of the Law on Consumer Protection.



Concretely, the court had to assess the following terms:The clause allowing the telecom operator to refuse the conclusion of a contract, or to terminate unilaterally a contract with the consumer, where the latter violates the terms of the contract, while at the same time requiring the consumer to make a prior notice of one month, in order to terminate the contract, where the telecom operator is in violation of the terms of the contract; The stipulation that the telecom operator can increase the price of the service without giving the consumer the corresponding right to cancel the contract, if the final price is too high in relation to the price agreed when the contract was concluded;The stipulation that the telecom operator can increase the price of the service without giving the consumer the corresponding right to cancel the contract, if the final price is too high in relation to the price agreed when the contract was concluded;


Practical experience of enforcing Directive 2009/22/EC by Practical experience of enforcing Directive 2009/22/EC by qualified entities (8)qualified entities (8)

The stipulation that the telecom operator can alter unilaterally the credit limit, agreed with the consumer and without giving a notice to the consumer. According to this term, the consumer is required to pay all sums for mobile telephone services, including those exceeding the agreed credit limit under the contract;

The stipulation that the telecom operator can terminate unilaterally the contract with the consumer, where the latter owes a debt towards the same supplier stemming from another contract between both parties, irrespective of the fact that the consumer is performing his obligations under the contract in question.



Subject matter of the claim: unfair marketing practiceAction for injunction to stop and to prohibit the use of unfair marketing practice used by the telecom operator consisting in the obligation imposed to consumers wishing to terminate the contract, not only to give a notice of one month to the seller, but also to submit an additional written statement for termination of the contact, which is to be submitted to the trader in additional deadline, set up by him. In the absence of such written statement for termination of the contract by the consumer, the telecom operator considers that the notification for the termination of the contract which is to be given one month before the expiry of the contract has been withdrawn and the contract is being renewed automatically. In this case the Court had to assess whether there has been violation of the provisions of the Law on Consumer Protection, i.e. whether the trader has imposed an excessive and not proportionate to the purpose obstacles outside the contract when the consumer wants to exercise his rights under the contract, including his right to terminate the contract.



The following claims were submitted to the court:- to order the cessation of the use of the above-mentioned practice;- to prohibit the use of the practice in the future;- to order the trader to make public the decision of the court.


Practical experience of enforcing Directive 2009/22/EC by qualified entities (11)

The administrative authority for consumer protection has prohibited a misleading marketing practice consisting in the provision of misleading information on the web page of the seller (the information contained on the web page of the trader stressed the possibility for consumers to have ‘unlimited telephone calls, SMS-s and unlimited access to the internet’, while in fact, they were provided only a limited access to telephone calls and SMS-s - up to 1500 minutes per month and restrictions in the speed of the internet traffic after running out of the initial MB quantity of the selected subscription program. The administrative order has been appealed in court by the trader and an action for injunction to stop and to prohibit the use of unfair marketing practice has been introduced



Subject matter of the claim: unfair marketing practiceAction for injunction to stop and to prohibit the use of unfair marketing practice used by a company for taxi services consisting in putting the sign of the competitor (“OK”), well known for the cheapest tariffs on the market, on the name of its own company and on the taxi cabs used by this company and this way creating confusion and misleading consumers that the taxi services offered by this company are being provided by the firm offering cheapest tariffs, when it is not.In this case the Court had to assess whether there has been violation of the provisions of the Law on Consumer Protection-‘marketing activity with regard to a service which creates confusion with another product, service, mark, trade name or another distinguishing sign of a competitor’.


Criteria for the use of cease and desist order by qualified Criteria for the use of cease and desist order by qualified entitiesentities

Criteria used by enforcement authorities to decide whether or not to initiate an action for injunction (cease and desist order):

high number of complaints; number of consumers damaged; amount of damage suffered by consumers; impact: direct and indirect impact on consumer welfare

and economy; when administrative enforcement by the authority fails or

when the trader does not comply with administrative orders and is appealing them in court.


Enforcement of the Directive 2009/22/EC Enforcement of the Directive 2009/22/EC

Qualified entities can apply for an order in respect of all infringements of the national consumer protection legislation;

General enforcement principles: The stop and desist order should be necessary and

proportionate; Business will normally be given a reasonable opportunity to

put matters rights; Wherever possible court action will only be taken after

undertakings have been sought; proceedings are brought by the most appropriate body:

with proper regard for other statutory regulatory means and non-statuary mechanisms


Enforcement of the Directive 2009/22/EC (Enforcement of the Directive 2009/22/EC (22))

Actions for injunctions are used rarely for cross-border infringements of EU consumer protection legislation;

However, they are used by consumer associations for national infringements, in order to have unfair commercial practices stopped or to cancel an unfair term in a contract.

Difficulties related to the enforcement: The major difficulties related with the actions for injunctions are the cost

of bringing an action, especially in another Member State, the complexity and length of the procedure and the limited scope of the injunction procedure;

The main obstacle to the actions for injunctions is the cost of bringing an action, in particular in the event of an infringement in another Member State;

These include the administrative costs of preparing the file, court fees and lawyers’ fees;

If the action is brought in another Member State, it will also entail translation costs;

Collection of evidence; The financial risk exists when the losing party has to bear all the costs of

the procedure and, in particular, pay the costs of the successful party.

35Belgrade - 24 October 2013

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Emil ALEXIEV

THANK YOU FOR YOUR ATTENTION!

36Belgrade - 24 October 2013

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