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declare Article 20 of Regulation No 1/2003 inapplicable in the present case on the basis of Article 277 TFEU and, consequently, annul European Commission Decision C(2019) 3761 of 13 May 2019;

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annul European Commission Decision C(2019) 3761 of 13 May 2019 on the basis of Article 263 TFEU;

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order the Commission to pay all of the costs.

1.

First plea in law, alleging that the contested decision is illegal in so far as it was adopted solely on the basis of documents seized during an inspection carried out beforehand on the basis of a decision that was itself illegal.

2.

Second plea in law, alleging that the contested decision is illegal in so far as it is based on Article 20 of Council Regulation (EC) No 1/2003 of 16 December 2002 on the implementation of the rules on competition laid down in Articles 81 and 82 of the Treaty (Text with EEA relevance) (OJ 2003 L 1, p. 1), a provision that is itself illegal and therefore inapplicable in the present case in accordance with Article 277 TFEU. That provision infringes the fundamental right to an effective remedy in that it does not allow undertakings to which a Commission inspection decision is addressed to bring proceedings to challenge the manner in which the inspection is carried out.

3.

Third plea in law, alleging infringement of the fundamental right to the inviolability of the home in that the contested decision is valid for an indefinite period and is both imprecise and disproportionate in scope.