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annul the defendant’s decision of 12 October 2021 (1) to reject the applicant’s tender in the procurement procedure MOVE/2020/OP/0008 ‘Legal, socio-economic and technical assistance in the fields of Energy and Mobility and Transport’, lot 5: ‘socio-economic assistance activities in the field of mobility and transport’;

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annul every consequent, intended or related measure, including even measures as yet unknown taken by the defendant in lot 5 of the aforementioned procurement procedure, and, in particular, annul the tender evaluation reports and any contract entered to with the successful tenderer; and

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order the defendant to pay the costs.

1.

First plea in law, alleging that the defendant made a manifest error of assessment by rejecting the applicant’s tender and thus infringed Article 168 (6) of Regulation (EU, Euratom) 2018/1046. (2)

2.

Second plea in law, alleging that the defendant infringed Article 41 of the Charter of Fundamental Rights of the European Union by rejecting the applicant’s tender and not considering the applicant’s explanations regarding the existence and integrity of its technical offer.