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Clarification or Confusion? How to reconcile the ECJ s rulings in Altmark and Chronopost? Introduction On 3 July 2003 the Court of Justice (hereinafter the ECJ ) set aside an earlier ruling of the Court of First Instance (hereinafter the CFI ) in the Chronopost case.1 Therein the ECJ ruled following the Opinion of Advocate General Tizzano delivered on 12 December 2002 that a market for offering the services of a universal service network, just as the one maintained by the Fr.
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