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Annul Commission Decision C(2024) 1172 final of 17 February 2024 relating to the recovery of EUR 122 662,74 (one hundred and twenty-two thousand six hundred and sixty-two euro and seventy-four cents), plus interest due, from Pinpoint Innovations Limited;

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Grant an extension of time for the completion of the grant agreement and the provision of funding;

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In the alternative, reduce the fine imposed on the applicant in exercise of the Court’s unlimited jurisdiction;

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Grant an order for the applicant’s costs.

1.

First plea in law, alleging that the defendant failed and/or refused to consider the force majeure clauses contained in the grant agreement in reaching its findings in the contested decision.

2.

Second plea in law, alleging that the defendant failed and/or refused to adopt a ‘flexible and favourable’ approach to the applicant, contrary to what was published in their FAQs in December 2020.

3.

Third plea in law, alleging that, even if the contested decision is in other respects deemed lawful, the sum found to be due and owing by the applicant to the defendant should be annulled or reduced, in light of (a) the global pandemic, which prevented the applicant from performing its duties and/or (b) the failure of the defendant to facilitate any engagement regarding the full implementation of ‘Project Tracworx’, when it was safe and legal to do so.