This is an HTML version of an attachment to the Freedom of Information request 'Notification of German Ancillary Copyright law'.


Ref. Ares(2019)7073401 - 15/11/2019
Message 202
Communication from the Commission - TRIS/(2014) 02051
Directive 98/34/EC
Translation of the message 201
Notification: 2013/0244/E
Forwarding of the response of the Member State notifying a draft (Spain) to comments (8.2)of Commission.
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(MSG: 201402051.EN)
1. MSG 202 IND 2013 0244 E EN 12-08-2013 15-07-2014 E ANSWER 12-08-2013
2. Spain
3A. Subdirección General de Asuntos Industriales, Energéticos, de Transportes, Comunicaciones y Medio
Ambiente.
Dirección General de Coordinación de Políticas Comunes y de Asuntos Generales de la Unión Europea.
Secretaría de Estado para la Unión Europea.
Ministerio de Asuntos Exteriores y de Cooperación.
C/ Serrano Galvache, 26, 4ª planta, Torre Sur (28071 Madrid)
Teléfonos: 91 379 84 64 y 91 379 17 80 
Fax: 91 379 84 01
Dirección correo electrónico: xxxxxxx@xx.xxxx.xx
3B. Subdirección General de Propiedad Intelectual.
Dirección General de Política e Industrias Culturales y del LIbro.
Secretaría de Estado de Cultura.
Ministerio de Educación, Cultura y Deporte.
4. 2013/0244/E - SERV60
5. -
6. Regarding the observations submitted by the European Commission pursuant to Article 8(2) of Directive
98/34/EC on the draft bill amending the revised text of the Law on Intellectual Property, approved by Royal
Legislative Decree 1/1996, of 12 April, and of Law 1/2000, of 7 January, on Civil Procedure, we wish it to be
known that the Council of Ministers, having carried out the mandatory procedures, at its session held on 14
February 2014, submitted the text to the Spanish Parliament, as the Bill amending the Revised Text of the Law on
Intellectual Property, approved by Royal Legislative Decree 1/1996, of 12 April, and Law 1/2000, of 7 January, of
Civil Procedure (Official Gazette of the Spanish Parliament of 21 February 2014), which is currently under
discussion by the parliamentary groups of the Spanish Lower House. 
With regard to the observations issued by the European Commission, the Spanish authorities would like to submit
the following considerations: 
1.- Transfer of rights to the audio recording producer. 
Firstly, the observations of the European Commission seek to clarify the concept of a “sufficient number of copies”,
which figures in the first paragraph of Article 110 bis, section 1 of the Revised Text of the Law on Intellectual

Property, approved by Royal Legislative Decree 1/1996, of 12 April (hereafter: TRLPI) in the version proposed by
the Draft Bill. 
Although it should be noted that none of the parties interested in the Draft Bill have requested the revision of the
concept of a “sufficient number of copies” during the public information procedure to which the text was submitted
between 22 March and 17 April 2013, following the observation of the European Commission, the draft has been
amended to read as follows: 
“1. If, fifty years from the date of the lawful publication of the audio recording or, where no publication has taken
place, fifty years from the date of its lawful communication to the public, the audio recording producer does not
offer enough copies for sale to reasonably meet estimated public demand in accordance with the nature and
purpose of the audio recording, or if the audio recording is not made available to the public in the manner
established in Article 20.2.(i), the performer may terminate the contract which transferred the rights to the
recording of his or her interpretation or performance to the audio recording producer.”
This aims to establish criteria to determine whether a sufficient number of copies have been physically put up for
sale, which is important in order to verify whether the unilateral termination of the contract by the performer is
lawful. 
Accordingly, the criterion has been chosen in accordance with the criterion under Article 4 TRLPI regarding the
number of copies considered sufficient to determine whether a work has been published. In this context,
“publication constitutes the dissemination by making available to the public a number of copies of the work which
reasonably meets the estimated public demand in accordance with its nature and purpose”. This wording comes
from Article 3.3 of the Berne Convention, which establishes that “[T]he expression ‘published works’ means works
published with the consent of their authors, whatever may be the means of manufacture of the copies, provided
that the availability of such copies has been such as to satisfy the reasonable requirements of the public, having
regard to the nature of the work”. 
2.- Private copying exception and fair compensation: 
Before answering the request for clarification and explanation regarding the various limits of the future regulation
on fair compensation for private copying in the Bill amending the Revised Text of the Law on Intellectual Property,
approved by Royal Legislative Decree 1/1996, of 12 April, and of Law 1/2000, of 7 January, of Civil Procedure,
(hereafter: “the Bill”), it should be noted that the text that was analysed by the services of the European
Commission has undergone amendments to its contents following the observations made by the Commission and
various national advisory bodies. Although the new wording resolves - partly in some cases - some of the concerns
raised by the questions submitted and the text, as previously mentioned, is currently the subject of negotiations
between parliamentary groups in the Spanish Lower House, Article 25 of that text is reproduced below, in the
version of the Bill which was submitted to the highest national consultative body, the Council of State, for its due
consideration. 
“Article 25. Fair compensation for private copying.
1. The reproduction of works distributed as books or publications which are for these purposes assimilated in
regulation, and of audio recordings, video recordings or other audio, visual or audio-visual copies made using
non-typographical technical devices or instruments, exclusively for their private use, not for professional or
business use, and for ends that are neither directly nor indirectly commercial, in accordance with Article 31,
sections 2 and 3, shall incur a single, fair compensation for each of the three types of copy mentioned above. 
Such compensation, in line with the General State Budget, is intended to compensate the intellectual property
rights forgone under the legal private copying limitation. 
2. Compensation shall be paid to the authors of the works indicated in the previous section, which are publicly
exploited using one of the methods mentioned in that section, and, in relevant cases and types of reproduction, to
the editors, audio recording and video recording producers and performers whose performances were recorded on
those audio recordings and video recordings. This right cannot be waived by authors, performing artists or
performers. 
3. The procedure to determine the amount of this compensation, which is calculated on the basis of the prejudice
caused to the beneficiaries listed in section 2, in accordance with the private copying limitation established in
Article 31, sections 2 and 3, and which will be included in the General State Budget on an annual basis, as well as
the procedure for the payment of such compensation, which will be effected through management entities, shall
comply with the regulations. 
4. In order to establish the amount of fair compensation, the following shall not be considered copies for private
use: 
a) copies recorded using digital copying equipment, devices or media acquired by legal persons, that have not
been made available, in law or in fact, to private users and that are clearly reserved for uses other than private
copying;
b) copies recorded by persons with prior authorisation to carry out the corresponding reproduction of the protected
works and performances in the exercise of their activities, under the terms of said authorisation;
c) copies obtained of works or performances which are distributed through effective technological measures which
prevent or limit the recording of private copies, where the copyright holder has not authorised the copy.
5. No obligation for compensation may arise from regulated situations in which prejudice to the rightholder is

5. No obligation for compensation may arise from regulated situations in which prejudice to the rightholder is
minimal. In no event may an obligation for compensation arise from the single and temporary recording by
individuals for their personal use of works to which they have obtained access through lawful means of image,
sound or audio-visual broadcasting, thereby enabling them to watch or listen to them at a more convenient time.
6. In determining the amount due in fair compensation, consideration may be given, in accordance with the
regulations, to whether the rightholders have used effective technological measures to prevent or limit private
copying, or to limit the number of private copies.” 
In addition, and having taken the observations made by the Council of State into consideration, the version of the
text in the Bill, which is currently under examination by the Lower House of the Spanish Parliament and is the
subject of negotiations between the Parliamentary Groups, is reproduced below: 
“Article 25. Fair compensation for private copying. 
1. The reproduction of works distributed as books or publications which are for these purposes assimilated in
regulation, and of audio recordings, video recordings or other sound, visual or audio-visual copies made using
non-typographical technical devices or instruments, exclusively for their private use, not for professional or
commercial use, and for ends that are neither directly nor indirectly commercial, in accordance with Article 31,
sections 2 and 3, shall incur a single, fair compensation for each of the three types of copy mentioned above.
Such compensation, in line with the General State Budget, is intended to compensate the intellectual property
rights forgone under the legal private copying limitation.
2. Compensation shall be paid to the authors of the works indicated in the previous section, which are publicly
exploited using one of the methods mentioned in that section, and, in relevant cases and types of reproduction, to
the editors, audio recording and video recording producers and performers whose performances have been
recorded on those audio recordings and video recordings. This right cannot be waived by authors, performing
artists or performers.
3. The procedure to determine the amount of this compensation, which is calculated on the basis of the prejudice
caused to the beneficiaries listed in section 2, in accordance with the private copying limitation established in
Article 31, sections 2 and 3, and which will be included in the General State Budget on an annual basis, as well as
the procedure for the payment of such compensation, which will be effected through management entities, shall
comply with the regulations.
4. In order to establish the amount of fair compensation, the following shall not be considered copies for private
use:
a) copies recorded using digital copying equipment, devices or media, acquired by legal persons, that have not
been made available, in law or in fact, to private users and that are clearly reserved for uses other than private
copying;
b) copies recorded by persons with prior authorisation to carry out the corresponding reproduction of the protected
works and performances in the exercise of their activities, under the terms of said authorisation.
5. No obligation of compensation may arise from regulated situations in which prejudice to the rightholder is
minimal. In no event may an obligation for compensation arise from the single and temporary recording by
individuals for their personal use of works to which they have obtained access through lawful means of image,
sound or audio-visual broadcasting, thereby enabling them to watch or listen to them at a more convenient time.
6. In determining the amount due in fair compensation, consideration may be given, in accordance with the
regulations, to whether the rightholders have used effective technological measures to prevent or limit private
copying, or to limit the number of private copies.”
In accordance with this version, the various questions submitted by the European Commission regarding this
article in its current version in the Bill are addressed below: 
• Regarding the criteria which determine that the situations described in Article 25, section 5 of the Law on
Intellectual Property, in the version proposed by the Bill, are considered to cause minimal damage and do not give
rise to an obligation of payment: 
The Bill refers to a further regulatory provision (Article 25.5 TRLPI in the wording proposed in the Bill), although it
goes on to outline a situation which, in any event, causes minimal prejudice and therefore does not give rise to an
obligation of fair compensation. This situation is the single and temporary reproduction by individuals for their
personal use of works to which they have obtained access through lawful means of image, sound or audio-visual
broadcasting enabling them to watch or listen to these at a more convenient time. Private copying is not subject to
fair compensation where it is understood that it does not have any real capacity to substitute the legal acquisition
of the protected works or performances that are copied and, therefore, either do not cause prejudice, or if they do,
it is of such little consequence as to be considered minimal. This situation is conditional on the functional nature of
such an action. Watching or listening to works or performances after they have been broadcast is only permitted
for the user’s enjoyment at a more convenient time or using a more convenient device. 

In order to achieve greater clarity and legal certainty, the aforementioned Bill seeks to determine the meaning of
lawful access to the work for its reproduction (Article 31.2.b TRLPI in the wording proposed by the Bill), in such a
way as to define the cases of lawful access and establish those situations which, falling within the scope of lawful
access, cause no or cause minimal prejudice. With regard to this last aspect, it must be concluded that in the
situation referred to in the aforementioned Article 25.5, it is understood that the copy does not prejudice the
rightholder given that no profits are lost, since neither the fact of watching or listening to the work after the
broadcast substitute a new licence agreement. 
• Regarding the criteria which determine, in Article 25, section 5, that only “the single and temporary reproduction
of works broadcast by public broadcasting organisations (as opposed to works broadcast by all broadcasting
organisations) causes minimal damage and, therefore, does not give rise to any obligation of payment: 
As already indicated above, the new version of Article 25, section 5 TRLPI in the Bill replaces “works broadcast by
public radio-broadcasting organisations” with “works to which they have obtained access through lawful means of
image, sound or audio-visual broadcasting” thereby removing any reference to the nature of the body which
broadcasts the work subject to private copying, whereby it is understood that it is no longer necessary to provide
an explanation regarding a version that has been amended in accordance with the Commission’s observations. 
• Regarding the date of the adoption of the regulations to determine situations in which prejudice to the rightholder
is minimal and how the Spanish authorities intend to guarantee that its adoption will not affect the system for the
calculation and payment of fair compensation in accordance with Royal Decree 1657/2012, of 7 December: 
The Bill (in the proposed version of Article 25.5 TRLPI) does not only recognise cases of minimal damage, as
established under preambular paragraph 35 of Directive 2001/29/EC (“in certain situations where the prejudice to
the rightholder would be minimal, no obligation for payment may arise”), but it goes further and establishes a legal
provision under the umbrella concept of minimal prejudice, to contribute to defining the concept. 
However, the Bill provides for further regulation (abovementioned Article 25.5) to address situations in which
prejudice to the rightholder is minimal and does not give rise to an obligation of compensation. This refers to a
future regulation, which would provide for the possibility of defining the legal concept, either by describing the
situations established in the law, or by regulating other situations that fall under the concept of minimal prejudice,
which will not be possible until the current Bill has been approved by the Spanish Parliament. 
Regarding the timeline for this regulatory development, it is not possible to provide an exact date since the text is
still at the preparatory stage, as indicated above. Until Parliament approves the current Bill, the provision in
question cannot be developed. 
Lastly, we consider that it is necessary to convey the idea that the approval of the current Bill, and the future Law
amending the revised text of the Law on Intellectual Property and the Law of Civil Procedure, will transfer in total
security the amendment both in law and through regulation of certain provisions of the abovementioned Royal
Decree 1657/2012, of 7 December, as a natural consequence of the provisions relating to private copying as
regards the requirements for legal access and the considerations regarding the calculation of fair compensation. 
• With regard to reproduction by individuals for private purposes (in other words, acts of private copying) under the
private copying exception (according to the proposed legislation) which would give rise to fair compensation: 
In the current wording of the Bill, acts of private copying are regulated as a limitation to the right to reproduction
and are therefore protected through the provision of fair compensation, as established in Article 5(2)(b) of the
abovementioned Directive 2001/29/EC.
In concrete terms, acts of private copying which fall within the scope of the private copying exception could include
situations in which a private copy is made of a work that has been accessed lawfully, such as a work contained on
a purchased storage device; copies of works containing technological measures limiting the number of copies that
can be made, provided that the copies are included in the number of copies permitted; or the reproduction of
works that incorporate measures that prevent their reproduction, where these have been lifted under Article
161.1(a) and 4 of the Revised Text of the Law on Intellectual Property, approved by Royal Legislative Decree
1/1996, of 12 April, and copies made through lawful acts of public communication which imply the broadcasting of
images, sounds or the simultaneous broadcasting of both. 
3.- The collective management of rights.
Regarding collective management of rights, the question is whether the authorisation requirement will also apply to
institutions established outside Spain which manage rights in Spain, and if this is the case, the European
Commission wishes to know how the Spanish authorities will justify the requirement of incorporation, which would
be introduced de facto in the draft Bill, taking into consideration the provisions of Directive 2006/123/EC, of 12
December 2006 on services in the internal market (OJ L 376, 27.12.2006, p. 36), and in particular its Article 16.
In this regard, it should be noted that the current wording of Article 147 TRLPI is a result of the amendment under
Law 25/2009, of 22 December, amending various laws for their adjustment to the Law on free access to service

Law 25/2009, of 22 December, amending various laws for their adjustment to the Law on free access to service
activities and their exercise, which was the last regulation which partially incorporated the aforementioned Directive
2006/123/EC into Spanish law. 
This amendment of the article removed the obligation on entities without an establishment in Spain to obtain an
appropriate authorisation from the then Ministry of Culture to “manage exploitation rights or other intellectual
property rights in their own name or for third parties, for and in the interest of various authors or other intellectual
property rightholders”, while it maintained the obligation of obtaining an authorisation for the collective
management of intellectual property rights, for entities with a permanent establishment, whether they performed
“obligatory” or “voluntary” collective management services. 
,The contents of Article 147 in the draft Bill submitted to the European Commission, which now appears as Article
148, has undergone changes, but of a different nature to the interpretation made by the Commission. The change
differs in that it makes the requirement of an administrative authorisation apply only to legally established entities
with an establishment in Spain, when they intend to manage rights subject to “obligatory” collective management. 
The intention of this amendment was to make the voluntary collective management of intellectual property rights
more flexible, even though Article 17(11) of Directive 2006/123/EC, made it possible to maintain the requirement
for entities that had an establishment in Spain of obtaining the corresponding authorisation for the voluntary
collective management of rights, a decision was taken to withdraw this requirement in the future. Removing this
authorisation, on the other hand, resulted in the general declaration of the voluntary provision of collective
management services for intellectual property rights, contained in the version of Article 147 TRLPI proposed by the
draft Bill. However, as indicated, the current text of the Bill which is currently before Parliament, has removed the
possibility of amending Articles 147 and 148 TRLPI, whereby these would, for the time being, remain as they
currently stand, following the amendment of the TRLPI under the abovementioned Law 25/2009, of 22 December: 
“Article 147 Requirements 
Legally constituted entities which have an establishment in Spain and which intend to provide, in their own name or
on behalf of a third party, management services for exploitation rights or other intellectual property rights, for and in
the interest of various authors or other intellectual property rightholders, must obtain the appropriate authorisation
from the Ministry of Culture, with a view to guaranteeing an adequate level of protection of intellectual property.
This authorisation must be published in the ‘Official State Gazette’. 
These entities, in order to guarantee the protection of intellectual property, must be not for profit and, pursuant to
the authorisation, may exercise the intellectual property rights entrusted to their management and will have the
rights and obligations established in this Title.”
“Article 148 Authorisation conditions 
A. The authorisation outlined in the previous article shall only be granted if the corresponding application is
accompanied with documentation which provides evidence that the entity meets the following conditions: 
a) That the statutes of the applicant meet the requirements established in this Title. 
b) That the information provided indicates that the applicant meet the conditions required to guarantee the
effective administration of the rights which are going to be entrusted to its management throughout the territory of
Spain. 
c) That the authorisation promotes the general interests of the protection of intellectual property. 
B. In order to evaluate whether the conditions set out in paragraphs (b) and (c) of the preceding paragraphs are
met, the following criteria will be taken into particular consideration: the applicant’s capacity to provide a viable
management of the rights entrusted; whether its statutes and material resources are suitable for providing this
service, the potential effectiveness of its management abroad, with particular attention to the overriding reasons of
public interest which the protection of intellectual property serves.
C. The authorisation shall be understood to have been granted if no notification is made to the contrary, within a
period of three months following the presentation of the application.”
4.- Enforcement of intellectual property rights. 
The various questions submitted by the European Commission are answered and commented on below: 
• Regarding the regulatory framework on data protection: Organic Law 15/1999, of 13 December on Data
Protection (LOPD), applies to any data processing carried out by the second section of the Intellectual Property
Commission (CPI). The safeguards are the general safeguards established in the LOPD and the implementing
regulations, except for cases in which a legal authorisation is required to obtain personal data, where provisions
are made for prior judicial supervision. The Spanish Data Protection Agency (AEPD) was consulted during the
preparation of the Bill and due consideration was given to its observations. An additional section 9 has been
included in Article 158 ter TRLPI in the version proposed as the Bill, clarifying that all the activities of the Second
Section of the CPI are subject to the LOPD. 
• Notion of “providers of information society services that directly violate intellectual property rights”. This notion

• Notion of “providers of information society services that directly violate intellectual property rights”. This notion
refers to those providers of information society services, defined under Directive 2000/31/EC and Law 34/2002, of
11 July, which usurp any of the exclusive rights reserved to rightholders under the Law on Intellectual Property.
The qualifier “directly” (Article 158 TRLPI in the version proposed by the Bill) has been deleted, considering it to be
redundant. 
• The notion of “sufficient links to Spain”. This is a concept that already appears in the relevant regulations in force
regarding the allocation of domain names under “.es” and it refers to the existence of links or relations with Spain
and in particular with the Spanish market. However, in the final version (Article 158 ter TRLPI, in the wording
proposed by the Bill) this has been deleted. Regarding the possible obligations arising from the provision of an
intermediation service to guarantee the effectiveness of the measure to bring the situation into line with the law,
the regulations in force in Spain require that such measures be objective, proportionate and non-discriminatory
(Article 11 of Law 34/2002, of 11 July, on information society and e-commerce services). 
• Enforcement of section 2, letter (B), of Article 158 ter. The conditions required to establish the liability of a
sophisticated content localisation service ensure that no intermediation service that limits itself to providing a
technical, neutral or passive service may be considered “responsible” for infringing the safeguards of intellectual
property rights in a digital environment. Therefore, it is highly improbable that an Internet service provider may be
considered responsible of the violation of section 2 letter (B) of Article 158 TRLPI in the wording proposed by the
Bill, because in general it shall not meet any of the conditions established under said provision. 
• Relation to Law 34/2002, of 11 July. The Bill strictly complies with the liability limitation regime established in the
aforementioned Law 34/2002, of 11 July, and therefore, with the regime provided under Directive 2000/31/EC. In
this regard, the aforementioned conditions, established in proposed Article 158, section 2, letter (B) TRLPI, are in
line with the jurisprudence of the Court of Justice of the European Union on the interpretation of Articles 12 to 15
of said Directive. Indeed, section V of the Preamble of the Bill expressly indicates that it does not affect the
limitations of liability established in Articles 14 to 17 of Law 34/2002, of 11 July. 
• Determination of “significant participation”. Although this requirement, contained in the Bill, eliminates the term
“participation”, it intends to exclude from the scope of the procedure one-off or negligible actions which,
nevertheless, may on occasion contribute or participate in an infringement committed by a third party. The Bill
(proposed Article 158 ter TRLPI) mentions the following factors for the consideration of significance: the Spanish
audience ratings of the service which participates in the infringement or the volume of protected works or
performances that such participation facilitates the infringement of. The current wording of the Bill simplifies and
improves the text. 
• The notion of “facilitating, specifically and on mass, the localisation of works and performances which are thereby
made available without authorisation”. The current wording of the Bill simplifies and improves the text, ensuring
that prosecuted conducts are significant, active, are not neutral and do not include cases of simple technical
intermediation. The required knowledge factor must be evaluated in accordance with existing jurisprudence,
especially that of the Court of Justice of the European Union on the interpretation of Articles 12 and 15 of Directive
2000/31/EC. Therefore, a technical host which merely offers the technical means to use localisation tools would, in
principle, not meet this condition.
• Article 158 ter TRLPI, in the wording proposed by the Bill applies, as explained above, both to those who infringe
intellectual property rights by usurping said rights as well as to providers that localise qualified contents meeting the
conditions established in section 2, letter (B) of said Article 158 ter. 
• Section 4 of Article 158 ter TRLPI in the wording proposed by the Bill applies to those considered “liable” for an
infringement of this procedure in agreement with the provisions in section 2 of Article 158 ter, in other words, it
applies both to those who infringe intellectual property rights and to providers who localize qualified contents which
meet the conditions established in section 2, letter (B) of Article 158 ter. As indicated above, an intermediation
service which is limited to a technical, neutral and passive service may not be considered “liable”. Regarding
platforms containing user-generated contents, the Bill does not make any specific provisions as to whether these
meet the conditions established in section 2, letter (B), of Article 158 ter, a question which must be considered on a
case-by-case basis. 
• Article 158 does not provide for the possibility of interrupting the final user’s access to the Internet. The Bill only
provides for the possibility of collaboration with the Internet service providers to block access to specific contents
or internet pages if the persons responsible for them have not removed offending contents once the CPI has
requested them to do so. The Bill expressly indicates (proposed section 5 of Article 158 TRLPI) that specific
justification must be provided for this measure, with due consideration of the effectiveness of other measures
available to the CPI. 
• Reference to “specifically directed at the territory of Spain”. This notion, contained in Article 4 of Law 34/2002, of
11 July, shall be interpreted in accordance with the jurisprudence of the Court of Justice of the European Union in
similar situations (among others C-585/08 and C-144/09). 
• The amount of the fine established in Article 158, section 6 TRLPI in the version of the Bill. The amount is
equivalent to the amount established for similar violations in cases where there is a failure to cooperate with the

equivalent to the amount established for similar violations in cases where there is a failure to cooperate with the
authorities, as for example in Article 38.3(g) of Law 34/2002, of 11 July, in connection with Article 39.1(b) of said
Law. It should be recalled that Article 158, section 6 TRLPI, in the version proposed by the Bill, sanctions the
reiterated failure to cooperate with the CPI by persons responsible for the violation of rights, manifested by the
failure to comply with the requirement to withdraw offending contents on two or more occasions. 
• Competence of the CPI to require the withdrawal of contents made available unlawfully. The Bill, maintaining the
current regulations of Law 2/2011, of 4 March, on the Sustainable Economy, in this regard, establishes that the CPI
may itself require, without a legal authorisation, the withdrawal of contents which, according to the relevant
administrative adversarial procedure, are considered to have been made available unlawfully. In the event of
failure to remove these voluntarily, the CPI must obtain the prior judicial authorisation foreseen for the restoration
of legality through the collaboration of the providers of intermediation, electronic payment and publicity services. 
• Review of the decisions of the CPI. All the decisions of the CPI, as administrative acts, may be reviewed by the
courts, through administrative proceedings. Therefore, the rulings issued under Article 158, section 4 TRLPI may
be reviewed in their entirety before said judicial bodies. 
**********
European Commission
Contact point Directive 98/34
Fax: +32 229 98043
email: xxxxxxxxxxxxxxxxx@xx.xxxxxx.xx