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annul Council Decision (CFSP) No 2021/142 and Council Implementing Regulation 2021/138 insofar as they concern the PKK (a.k.a. KADEK a.k.a. KONGRA-GEL);

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the Applicant additionally seeks an award of costs of litigation with interest, which will be specified at a later stage.

1.

First plea in law, alleging that Council Decision (CFSP) 2021/142 (1) and Council Implementing Regulation 2021/138 (2) are void insofar as they concern the applicant because they are in violation of the principle of legal certainty and/or of Article 1(2) of Council Common Position 2001/931/CFSP (3) and/or of Article 2(3) of Council Regulation No 2580/2001. (4) The applicant claims that the Council has failed to provide a clear and precise identification of the conceptualization of the PKK.

2.

Second plea in law, alleging that Council Decision (CFSP) 2021/142 and Council Implementing Regulation 2021/138 are void insofar as they concern the applicant because the applicant cannot be qualified as a group or entity involved in terrorist acts as defined in Article 1(3) of Council Common Position 2001/931/CFSP.

3.

Third plea in law, alleging that Council Decision (CFSP) 2021/142 and Council Implementing Regulation 2021/138 are void insofar as they concern the applicant because no decision by a competent authority has been taken in the meaning of Article 1(4) of Council Common Position 2001/931/CFSP.

4.

Forth plea in law alleging that Council Decision (CFSP) 2021/142 and Council Implementing Regulation 2021/138 are void insofar as they concern the applicant because the Council has not conducted any proper review as required by Article 1(6) of Council Common Position 2001/931/CFSP.

5.

Fifth plea in law, alleging that Council Decision (CFSP) 2021/142 and Council Implementing Regulation 2021/138 are void insofar as they concern the applicant because the decision and implementing regulation do not comply with the requirements of proportionality and subsidiarity.

6.

Sixth plea in law, alleging that Council Decision (CFSP) 2021/142 and Council Implementing Regulation 2021/138 are void insofar as they concern the applicant because they do not comply with the obligation to state reasons in conformity with Article 296 of the Treaty on the Functioning of the European Union.

7.

Seventh plea in law, alleging that Decision (CFSP) 2021/142 and Council Implementing Regulation 2021/138 are void insofar as they concern the applicant because they infringe upon the applicant’s rights of defense and the applicant’s right to effective judicial protection and remedy.