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annul the European Commission’s decision (EU) of 28 June 2024 C(2024) 4623 final on the State aid SA. 110687/SA.110688 – (2024/N) Sweden – Denmark, Restructuring of SAS Group (1); and

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order the European Commission to pay the costs.

1.

First plea in law, alleging that the aid falls outside the material scope of the Guidelines on State aid for rescuing and restructuring non-financial undertakings in difficulty (‘R&R Guidelines’).

2.

Second plea in law, alleging that the Commission misapplied the R&R Guidelines, and committed a manifest error of assessment regarding demonstration of the risk of disruption of an important service and the systemic role of SAS.

3.

Third plea in law, alleging that the Decision does not establish that the restructuring plan is realistic, coherent and far-reaching, and that it is apt to restore SAS’ long-term viability within a reasonable period of time and without relying on further State aid.

4.

Fourth plea in law, alleging that the Decision does not establish the appropriateness of the aid.

5.

Fifth plea in law, alleging that the Decision does not establish the incentive effect of the aid.

6.

Sixth plea in law, alleging that the Decision does not establish the proportionality of the aid.

7.

Seventh plea in law, alleging that the Decision does not adequately review the negative effects of the aid.

8.

Eighth plea in law, alleging that the Commission should have initiated the formal investigation procedure.

9.

Ninth plea in law, alleging that the European Commission violated its duty to state reasons.