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annul the decision of the Commission, concretely, the individual legal act ‘Recovery Order and Debit Note’ issued by the European Commission, DG for Communications Networks, Content and Technology, Ref. ARES(2021)1955613, on 18 March 2021;

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return the financial applications to the European Commission audit process and claim the relevant costs admissible according to the grant agreement ‘Slovak Safer Internet’, No. SI-2010-SIC-1231002;

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order the Commission to pay the costs and expenses of the proceedings.

1.

First plea in law, alleging the annulment of the defendant’s decision and recovery order Ref. ARES(2021)1955613 due to infringement of an essential procedural requirement, infringement of the Treaties or of any rule of law relating to their application, or misuse of powers, particularly improper legal evaluation of facts and findings (breach of right of defence, breach of right to good administration, breach of principle of proportionality, principle of legal certainty, rule of law, principle of legal expectations and non-retroactivity, improper legal evaluation of facts and findings of the Audit 12-INFS-024 and follow-up Audit 15-NR01-044).

2.

Second plea in law, alleging that the defendant be ordered to proceed to pay the eligible costs to the applicant as the original beneficiary and the contractual party to the grant agreement No. SI-2010-SIC-123002 — ‘Slovak Safer Internet’, in accordance with the valid and effective grant agreement, based on the fact that the defendant has the competence to deal with issues of project implementation and financial transfers in relation to the valid and effective contract between the defendant and the applicant.

3.

Third plea in law, alleging that the defendant be ordered to reimburse the costs and expenses of the proceedings. In accordance with the above-mentioned arguments and arbitrary character of the contested decision, the applicant seeks reimbursement of the costs and expenses connected with the proceedings before the General Court of the European Union as well as the costs and expenses spent for the legal assistance in relation to this claim.