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annul the European Commission Decision (EU) of 9 September 2024 on State aid SA.43260 (2018/C) implemented by Germany in favour of Flughafen Frankfurt Hahn GmbH and Ryanair DAC (1) insofar as it finds that unlawful and incompatible State aid was granted to Ryanair, and

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order the European Commission to pay the costs related to the proceedings.

1.

First plea in law, alleging that the Decision violates Articles 41 and 52 of the EU Charter of Fundamental Rights.

2.

Second plea in law, alleging that the Commission violated the limitation period for the recovery of State aid and failed to discharge its burden of proof and/or failed to provide adequate reasoning.

3.

Third plea in law, alleging that the Commission committed manifest errors of assessment of the renewability and profitability of the 2005 Marketing Agreement when applying the Market Economy Investor Test.

4.

Fourth plea in law, alleging that the Commission committed a manifest error of assessment of the indirect beneficiary of the 2017 Marketing Agreement, i.e. Frankfurt Hahn Airport, based on an incomplete assessment of the relevant facts.

5.

Fifth plea in law, alleging that the Commission disregarded the Land Rheinland Pfalz and Frankfurt Hahn Airport’s actual need for the marketing services, and the resultant satisfaction of the Market Economy Purchaser Test.

6.

Sixth plea in law alleging that the Commission committed a manifest error of assessment of the amount of alleged State aid.