In AMS Neve Limited v Heritage Audio SL (2018 EWCA Civ 86), the Court of Appeal of England and Wales has considered the issue of which member state's courts would have jurisdiction to hear a claim for infringement of an EU trademark where an online advertisement created in one member state bearing the infringing mark targeted consumers in another member state. The Court of Appeal concluded that it was necessary to make a reference to the Court of Justice of the European Union (ECJ).

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