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annul Decision C(2019) 5361 final of the Commission;

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annul, or in the alternative, reduce substantially the amount of the fine;

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order the Commission to pay the costs.

1.

First plea in law, alleging that the Decision is the result of grave procedural irregularities that have irreparably infringed Qualcomm’s rights of defence.

2.

Second plea in law, alleging that in defending the relevant market and in finding Qualcomm dominant, the Decision commits manifest errors of assessment of fact and law and fails to state adequate reasons.

3.

Third plea in law, alleging that the Decision fails to apply the correct legal standard thereby committing manifest errors of law.

4.

Fourth plea in law, alleging that the Decision’s predation theory is illogical and unsupported by evidence.

5.

Fifth plea in law, alleging that in reconstructing alleged ‘effectively paid’ prices, the Decision commits manifest errors and fails to state adequate reasons.

6.

Sixth plea in law, alleging that the Decision’s allocation of non-recurring engineering expenses is manifestly incorrect.

7.

Seventh plea in law, alleging that the Decision manifestly fails to establish an appropriate cost benchmark.

8.

Eighth plea in law, alleging that the Decision’s price-cost analysis is manifestly incorrect.

9.

Ninth plea in law, alleging that in finding that Qualcomm’s prices foreclosed Icera and produced consumer harm, the Decision commits manifest errors of law and of appraisal.

10.

Tenth plea in law, alleging that the Decision manifestly errs in finding that Qualcomm’s pricing was the implementation of a plan to exclude Icera.

11.

Eleventh plea in law, alleging that in dismissing the objective justification, the Decision commits a manifest error of appraisal and fails to state adequate reasons.

12.

Twelfth plea in law, alleging that the Decision is not adequately reasoned.

13.

Thirteenth plea in law, alleging that the Decision’s findings regarding the duration of the alleged infringement are manifestly incorrect.

14.

Fourteenth plea in law, alleging that the Decision manifestly errs in imposing and calculating the fine.

15.

Fifteenth plea in law, alleging that in establishing the Commission’s jurisdiction and the alleged effect on trade, the Decision commits manifest errors of law, fact and assessment and fails to state adequate reasons.