Responses to the whole
of your industrial needs

 

Réseaux de distribution, Concurrence

The notion of vertical and horizontal cartels in competition law

Ensuring healthy competition: Competition law, via Article 101 TFEU, prohibits anti-competitive cartels. Horizontal or vertical, these coordinations are strictly regulated, with specific exemption regimes. Let's break it down

 

Réseaux de distribution, Concurrence

Franchise or selective distribution: which contract to choose?

Do you want to replicate a proven concept or control the image of your products? The franchise transmits know-how, selective distribution selects resellers. Two logics, a decisive choice for your network.

 

Produits, Consommation, Publicité

Comparative advertising: legal framework and limits

Comparative advertising, a powerful marketing tool, is strictly regulated by law to ensure fair information and fair competition.

 

Réseaux de distribution, Concurrence

Sales Agent: an original indemnity calculation

The Court of Appeal of Rennes recalls the principle of nullity of the limitation clauses of the compensation due to a commercial agent but uses an original approach for the calculation of the compensation

 

Immobilier commercial

The delivery of the commercial premises: an obligation at all times for the lessor.

The lessor is required with regard to the lessee to deliver the premises and to ensure their peaceful enjoyment. Failure to comply with these essential obligations is punishable. Thus, it is in the lessor's interest to invoke the statute of limitations against the lessee who is the victim of a failure to deliver. But what is this prescription and from when does it run? It is to these questions of law that the judgment of the Court of Cassation of 10 July 2025 answers.

 

Immobilier commercial

Optimize rent management in commercial real estate

At the conclusion of the lease, the rent is set freely by the parties. However, it may change during the lease or when it is renewed.
The drafting of contractual clauses is therefore essential to anticipate and optimize the management of rents.

 

Immobilier commercial

Right to repentance and expert fees

When following a leave with refusal of renewal, the lessor exercises his right of repentance, he must bear all the costs of the proceedings, including the lawyer's fees, but also those related to the amicable expertise carried out by the lessee.

 

Réseaux de distribution, Concurrence

Analysis of recent sanctions in competition law

Competition law sanctions in France and the European Union were particularly prominent in 2024 and 2025, with record amounts and emblematic cases concerning anti-competitive practices, cartels and abuse of dominant position.

 

Réseaux de distribution, Concurrence

How to create and structure a distribution network: legal guide

Do you want to deploy a high-performance and secure distribution network? This legal guide offers you the keys to choosing the right contract (franchise, selective distribution, mandate management, etc.), mastering the steps and avoiding the risks of competition law.

 

Immobilier commercial

Secure the drafting and assignment of the commercial lease

The drafting or assignment of a commercial lease requires rigorous legal certainty. Checks, clauses, appendices: every detail counts. The support of a specialized lawyer guarantees a solid contract and protects the lessor as a tenant.

 

Réseaux de distribution, Concurrence

Expanding a Franchise Network: Best Practices

Expanding a franchise network cannot be improvised. From concept validation to legal structuring, each step must be mastered to ensure a secure and legally compliant development.

 

Immobilier commercial

Law to simplify economic life: to follow for lessees!

The draft Law for the Simplification of Economic Life will be studied by a joint joint committee.
Discover the preludes of this Act, whose provisions directly concern the subject of commercial leases and, in particular, the protection of lessees.

 

Réseaux de distribution, Concurrence

Competition law: how to protect your company?

To protect a company under competition law, it is essential to understand prohibited practices and defense and prevention mechanisms.

 

Produits, Consommation, Publicité

The liability regime for defective products

Liability for defective products is characterized by the obligation on the producer, manufacturer, distributor, seller or lessor of a good not offering the security that can legitimately be expected, to repair the damage caused by it.

 

Réseaux de distribution, Concurrence

International development of a franchise network: legal aspects

Whatever the reasons that may lead a network to expand abroad, such an operation raises specific legal questions

 

Immobilier commercial

Indexation clause deemed unwritten: restitution of overpayment

Gouache Avocats obtained a particularly important decision, in which a lessor had to return more than €15,000 in overpayments of rent, due to the indexation clause deemed unwritten. A decision that illustrates the importance of precise drafting of the clauses of the commercial lease.

 

Produits, Consommation, Publicité

Advertising, promotions and consumer law: what the law says

In the interests of consumer protection, the legislator establishes a legislative framework relating to advertising communications and promotional commercial operations.

 

Produits, Consommation, Publicité

Focus on the new transparency obligations of the Eco-design Regulation

Regulation (EU) 2024/1781 of 13 June 2024 lays down new transparency requirements for economic operators concerning the management of unsold items and the provision of a digital passport.

 

Produits, Consommation, Publicité

Publication of priority areas for the application of the Eco-design Regulation

In a publication of 16 April 2025, the European Commission established the list of priorities for the years 2025-2030 for the implementation of the Eco-design Regulation of 13 June 2024.  

 

Produits, Consommation, Publicité

Can an unfair practice form the basis of an action for unfair competition

In a judgment of 14 May 2025, the Court of Cassation questioned the possibility of bringing an action for unfair competition relating to a commercial practice, with no direct link to the consumer, whereas this practice would not substantially alter the consumer's economic behaviour.  

 

Produits, Consommation, Publicité

New DGCCRF guidelines on payment terms

The agents of the DGCCRF are authorized to search for and note breaches of the regulations on payment terms between companies and in public procurement contracts. In the event of exceeding a maximum period, it may in particular impose an administrative fine of up to 2 million euros or, in the event of repetition within two years, 4 million euros .  

 

Immobilier commercial

Payability of the Domestic Waste Removal Tax?

If it is now accepted that the lessor can only invoice its lessee for the charges and taxes expressly provided for in the lease, what about the Domestic Waste Removal Tax when the lease refers to the law of 1 September 1948? 

 

Immobilier commercial

Right of option and return of premises

The right of option can be particularly useful in the event of renewal of the commercial lease. Indeed, the tenant can, during the rent fixing procedure and after having exercised his right of option, return the premises quickly: there is no need to wait for the three-year deadline. 

 

Immobilier commercial

Is the obligation to take out new insurance a reason for uncapping?

If the lessor is required to take out civil liability insurance, this obligation constitutes a significant modification and a reason for de-capping the rent. The fact that the lessor has already taken out such insurance, before it becomes mandatory, does not deprive it of its significant character allowing it to escape the de-capping.

 

Immobilier commercial

Legality of the clause obliging the parties to call the lessor to the deed of assignment

Do not constitute a prohibitive clause, leading to prohibit any transfer, within the meaning of Article L145-16 of the Commercial Code, the stipulations according to which the lessor will be called upon to any transfer of goodwill. 

 

Immobilier commercial

Indexation clause deemed unwritten: what is the tenant's claim?

A deemed unwritten indexation clause is deemed never to have existed. The tenant may thus, within the limit of the 5-year limitation period under ordinary law, request the reimbursement of overpaid rents.

 

Immobilier commercial

Use of the termination clause and judicial termination

The order to pay, referring to the termination clause, must specify the date from which the termination must occur. Judicial termination must be justified by a sufficiently serious breach. 

 

Réseaux de distribution, Concurrence

The regime of penalties for contractual non-performance

The Court of Cassation provided details on the application of the rules of the Civil Code governing contractual non-performance.

 

Réseaux de distribution, Concurrence

Online video games cannot be resold second-hand

The Court of Cassation ruled on the issue of exhaustion of the right of distribution of a video game provided online.

 

Réseaux de distribution, Concurrence

Termination of commercial relationship: clarifications on the rules of notice

The Court of Cassation clarifies the criteria for assessing notice in the event of termination of a commercial relationship, stressing the importance of the duration of the relationship and economic dependence. An essential analysis for companies concerned with securing their contractual practices.

 

Réseaux de distribution, Concurrence

Business Breakdown: Parent Company Liability and Partner Dependency

The Paris Court of Appeal ruled on the responsibility of the parent company of the author for a sudden termination of the commercial relations established in the event of interference by the latter in the management of his daughter and the criteria to be taken into account in the event of economic dependence of the partner.

 

Réseaux de distribution, Concurrence

Anti-Competitive Practices and Jurisdiction

The Paris Court of Appeal has sole jurisdiction to hear disputes relating to restrictive competition practices and anti-competitive practices. 

 

Réseaux de distribution, Concurrence

A deviation from standard prices may constitute a cartel

  While the derogation mechanism provided for in the framework contracts is not illegal in principle, its implementation can concretely result in a vertical agreement on prices.

 

Réseaux de distribution, Concurrence

Injunction of dissolution of a competing bar: lack of jurisdiction of the ADLC

  The Court of Appeal of Paris confirms the incompetence of the Competition Authority to hear a decision taken by the President of the Bar to oust a newly created competing bar within the jurisdiction of its bar.

 

Produits, Consommation, Publicité

Franchise, where the limit of canvassing is located

The Court of Cassation delivered an interesting judgment on the scope of a territorial exclusivity clause stipulated in a franchise agreement, in the event of canvassing actions carried out by a franchisee on the exclusive territory of another franchisee in the same network. 

 

Produits, Consommation, Publicité

The use of a competitor's trademark in a paid advertisement constitutes an act of infringement.

The firm has just obtained an interesting decision in a dispute concerning the unauthorized use of a client's brand in a paid advertisement published on a search engine to divert customers to its site.  The Nancy Court of Justice has just condemned this competitor for the acts of infringement committed.  

 

Produits, Consommation, Publicité

Compensation for damage suffered in unfair competition through the assessment of loss of profits

In a judgment of 2 April 2025, the Paris Court of Appeal ruled on the assessment of the economic damage resulting from acts of unfair competition by taking into account the loss of income.

 

Produits, Consommation, Publicité

Can an article aimed at a competitor characterize a deceptive commercial practice

It is to this question that the Court of Appeal of Paris has just answered, in a judgment rendered on March 14, 2025  (RG No. 22/16356), in the context of a dispute between the company La Capsule, the companies La Loco and Le Wagon, competitors in the sector of training in computer coding. 

 

Produits, Consommation, Publicité

Clarification of the concept of "comparative advertising"

In a judgment of 8 May 2025, the CJEU states that a service for online comparison of products or services provided by a company that is not a "competitor" does not fall within the concept of "comparative advertising".

 

Produits, Consommation, Publicité

Reinforcement of interoperability obligations under the bonus of abuse of a dominant position

In a judgment of 25 February 2025, the Court of Justice of the European Union was asked whether the refusal by an undertaking in a dominant position to ensure interoperability between its platform and an application of a third party undertaking may constitute an abuse of a dominant position.

 

Produits, Consommation, Publicité

The CJEU applies the concept of economic entity to a breach of the GDPR

 The Court of Justice of the European Union was asked about the concept of an undertaking, in the presence of a parent company and its subsidiary, for the determination of the amount of the administrative fine imposed for a breach of the General Data Protection Regulation. 

 

Immobilier commercial

Is the commercial lease continued in the event of collective proceedings?

The opening of collective proceedings, whether a safeguard, a reorganization and even a liquidation, does not automatically entail termination of the lease. 

 

Immobilier commercial

Pharmacy – rent - evidence and mediation

Rent fixing proceedings are sometimes lengthy, as the parties do not always provide proof of their claims. This is why a judicial expert is appointed. Now, the court can lengthen this procedure by ordering the parties to meet with a mediator. 

 

Immobilier commercial

Accessory eviction compensation and age of the tenant

In terms of eviction, and in particular with regard to the costs of re-employment, it is now clear that it is up to the lessor to prove that the lessee will not resettle so that these are not due. What if the lessee is 80 years old?!? 

 

Immobilier commercial

Interpretation of the clause relating to charges and recovery of undue

A tenant may claim reimbursement of charges if he demonstrates a lack of express stipulation in the commercial lease imposing these charges on him. 

 

Immobilier commercial

The effects of a termination clause inserted in a commercial lease may be suspended

The lessee who is issued an order for the termination clause may request deadlines to perform his obligation, including when the breach alleged by the lessor does not concern the payment of rents.  

 

Immobilier commercial

Assignment of goodwill in fraud of a creditor's rights

The Paulian action, organized in Article 1341-2 of the Civil Code, makes it possible to make unenforceable the transfer of goodwill having the effect of transferring it by replacing it with a sum of money more difficult to seize, and depriving the creditor of the faculty to assert his rights. 

 

Réseaux de distribution, Concurrence

The difficult waiver of compensation for the principal's losses

The Paris Court of Appeal is not satisfied with a waiver clause.

 

Réseaux de distribution, Concurrence

Opposability of the jurisdiction clause

A company necessarily accepts the transfer of a contract to a new seller, including the jurisdiction clause it agrees to, by continuing to place orders and accept deliveries from that company.   

 

Réseaux de distribution, Concurrence

Serious fault of the commercial agent discovered after the termination and compensation

The Court of Cassation confirms that only serious misconduct directly causing the breach of contract can deprive a commercial agent of his compensation. Increased protection for agents, but more complex management for principals. 

 

Réseaux de distribution, Concurrence

Restrictive competition practices and international public policy

Does the law of restrictive practices belong to international public policy or not? 

 

Réseaux de distribution, Concurrence

Confirmation of ADLC sanctions against Luxottica and Essilor

On December 12, 2024, the Paris Court of Appeal had the opportunity to review two decisions rendered by the Competition Authority relating to practices implemented in the glasses and optical lenses sectors. 

 

Réseaux de distribution, Concurrence

Opinion of the Competition Authority on rating systems

In an opinion of 9 January 2025, the Competition Authority makes recommendations to publishers of rating systems for products and services. 

 

Réseaux de distribution, Concurrence

Minister's Action: Enhanced evidentiary requirements for subjecting to significant imbalance

  The Court of Appeal clarifies its evidentiary requirements regarding proof of submission in the event of action by the Minister of Economy on the basis of significant imbalance.  

 

Réseaux de distribution, Concurrence

The change of control of the franchising company does not constitute a violation of the intuitu personae nature of the franchise agreement

A franchisor has made a modification to the repair of its shareholding by including in its capital a new legal entity shareholder up to 80%, the historical natural person shareholder retaining 20% of the share capital.  Informed of this operation like all franchisees, one of them decides to …

 

Réseaux de distribution, Concurrence

Reciprocal concessions and validity of a transactional protocol (Tout-la-Franchise, July 2015)

In accordance with Article 2044 of the Civil Code, a settlement protocol, in accordance with Article 2044 of the Civil Code, is a contract by which the parties terminate a dispute arising, or prevent a dispute from arising, by making reciprocal concessions. Under the terms of a settlement …

 

Unfair competition action: a strategic tool at the service of brands (Argus de l 'ensign, April 2015)

The decision rendered on December 22, 2014, by the Commercial Court of Paris against companies of the OPTIC 2000 group marks a new stage in the legal strategy of the OPTICAL CENTER group, which has introduced in recent years several proceedings in unfair competition against competing brands.…

 

Réseaux de distribution, Concurrence

CJEU: Strengthening the right to reparation for victims of anti-competitive practices

In a decision of 28 January 2025, the CJEU ruled that national regulation preventing victims of anti-competitive practices from transferring their rights for a group action is not in conformity with Union law if the individual action is impossible or excessively difficult. 

 

Réseaux de distribution, Concurrence

Significant imbalance: details of the Minister's action

The Paris Court of Appeal reaffirms the civil tort nature of the Minister's action under domestic law.

 

Réseaux de distribution, Concurrence

Pricing and Online Sales in the Home Appliances Industry

After eleven years of proceedings, the Competition Authority sentences 12 companies for vertical agreements between manufacturers and distributors (ADLC Decision No.24-D-11 of 19 December 2024) 

 

Relations clients fournisseurs

Legal set-off and assignment of claims in the event of collective proceedings

The Court of Cassation specifies that the legal compensation can only be carried out for the benefit of the assignee in respect of an assigned receivable after notification of the assignment to the debtor, which must take place before the judgment opening the collective proceedings of the latter which takes effect from the day of its pronouncement. 

 

Distribution Networks, Competition

Calculation of the commercial agent's allowance

There is no need, for the purposes of assessing the termination indemnity of the commercial agent, to take into account circumstances subsequent to the termination of the contract, such as the conclusion by the agent of a new contract with a view to prospecting the same clientele for another principal. 

 

Relations clients fournisseurs

Brutal termination of established business relationships

By a judgment of 17 January 2025, the Paris Court of Appeal confirmed the applicability of the basis for the sudden termination of commercial relations in the audiovisual sector. 

 

Réseaux de distribution, Concurrence

Is sending the dip within the legal deadline sufficient to exclude the licensor's liability?

Under the terms of Article L.330-3 of the Commercial Code, the transmission of a pre-contractual information document, or dip, is mandatory within 20 days before the signing of the contract when a person makes available to another, a commercial name, a brand or a sign, requiring an exclusivity or quasi-exclusivity commitment for the exercise of his activity. 

 

Produits, Consommation, Publicité

The calculation of a price reduction listing must be based on the previous price

In a judgment of 26 September 2024, the CJEU states that the announcement of a price reduction must be calculated on the actual basis of the previous price in accordance with Article 6a of Directive 98/6.

In the context of this case, the Court of Justice of the European Union (CJEU) was seized by the Court of Düsseldorf in Germany concerning Aldi's advertising practices.  

 

Produits, Consommation, Publicité

Clearly personalised and right of withdrawal for a website

By a judgment of 17 October 2024, the Douai Court of Appeal ruled on the concept of clearly personalized property applied to a website with regard to the benefit of the right of withdrawal.  

 

Produits, Consommation, Publicité

The ban on the expressions “soy steaks” and “vegetable sausages” annulled

By two decisions of 28 January 2025, the Council of State aligned itself with the position of the CJEU by affirming the annulment of the decrees prohibiting the use of the expressions "soya steaks" and "vegetable sausages".

 

Produits, Consommation, Publicité

Control of unfair terms in consumer credit agreements

By a judgment of 13 March 2025, the CJEU ruled on the applicability of the review of unfair terms within a consumer credit agreement.   

 

Produits, Consommation, Publicité

Draft Omnibus Directive, its impacts on the CSRD

On 26 February 2025, the European Commission published a proposal for an Omnibus Directive, aimed at simplifying European regulations on sustainability and due diligence issues and reducing the administrative burden on companies in this respect.

 

Produits, Consommation, Publicité

DGCCRF: Is the evidence by questionnaire fair?

The Court of Cassation, in a judgment of 29 January 2025, took a position on the issue of the unfairness of employment by agents of the DGCCRF, standardized questionnaires limiting the freedom of response of interviewees.

 

Immobilier commercial

Denial of the right to the status of commercial leases

When can the Lessee’s lack of registration, which conditions the right to renewal, be invoked by the Lessor? Is it possible to deny the right to renewal during the procedure to have the rent of the renewed lease fixed? Right to renewal of the commercial lease: when can it be denied? …

 

Immobilier commercial

Compensation at the end of the lease: Accession and restitution of the premises

When drafting the lease and returning the premises, how to anticipate the difficulties relating to the condition of the leased premises, in particular with regard to the accession and restoration clauses stipulated in the commercial lease? Many questions arise during the return of the premis…

 

Immobilier commercial

Local shops: Limit the risk of uncapping!

In the absence of other reasons, the lessors attempt to de-cap the rent of the renewed lease by invoking a modification of the local commercial factors. However, such a change may be limited when it comes to convenience stores. During the renewal of the commercial lease, in the event of an i…

 

Le Point interview: Gouache Avocats: cross-functional support for distributors

Gouache Avocats is a Parisian law firm dedicated to the distribution operation. With its unique and transversal positioning and an innovative vision, the firm wishes to reinvent the client/lawyer relationship. Jean-Baptiste Gouache, associate lawyer and founder of Gouache Avocats, testif…

 

Commercial rents workshop: reducing costs

Workshop organized by the Trade Alliance, with the participation of Stéphane Ingold, in charge of Real Estate at Gouache Avocats June 15, 2023 from 9:30 a.m. to 12:30 p.m. at the premises of the Alliance du Commerce, in Paris The weight of rents and rental charges continues to represen…

 

NEW APPOINTMENT:

WHAT ROLES OF THE GROUP IN COMMERCIAL LEASING? Thursday, June 15, 2023 from 9:30 a.m. to 12:30 p.m. The next FCA workshop will be dedicated to the different roles played by cooperative and associated trade groups in commercial leasing. What are the different activities of the group? Lesse…

 

Réseaux de distribution, Concurrence

Derogation from the commercial agent's right to commission

The commercial agent may be contractually derogated from the right conferred by Directive 86/653/EEC to receive a commission for the transaction concluded, during the term of the agency contract, with a third party whose clientele this agent has previously obtained for transactions of the sa…

 

Réseaux de distribution, Concurrence

The hybrid marketplace and counterfeiting

If the user of a hybrid marketplace may have the impression that it markets counterfeit products itself, it may then be prosecuted for counterfeiting. Two questions were referred to the Court of Justice of the European Union for a preliminary ruling in two cases between Christian Louboutin…

 

Réseaux de distribution, Concurrence

Assignment of goodwill and distribution contract

The transfer of a business is not worth and does not entail the transfer of a distribution contract. In a decision of 19 October 2022, the Commercial Chamber of the Court of Cassation laid down, in a fairly conventional solution, the principle that the transfer of a business is not worth and…

 

Réseaux de distribution, Concurrence

Deductible - Information obligation and blocking minority

The nullity of a franchise agreement is pronounced for a lack of information from the franchisee on the existence of a blocking minority and its consequences. The Commercial Court of Caen, in a decision of 25 January 2023, declared the nullity of a participatory franchise agreement for lack …

 

Réseaux de distribution, Concurrence

Unfair terms in contracts with app developers

The provisions sanctioning significant imbalance constitute a mandatory law. It is on this basis that 6 clauses of the contracts concluded between Apple and application developers were declared abusive by the Commercial Court of Paris. On December 19, 2022, the Commercial Court of Paris iss…

 

Immobilier commercial

Transfer of catering business: transmit licenses

When it comes to selling alcohol on-site, restaurants are a “subset” of drinkers. Thus, the restaurateur selling his business, which offers alcoholic beverages for sale, normally has either a Beverage License or a Catering License. The purchaser must, for his part, meet personal conditions …

 

Immobilier commercial

Renewed lease price in shopping malls: impact of property tax

Why is it necessary, when setting the price of the renewed lease, to deduct the amount of property tax from the rental value, even in shopping malls? A practice that has become commonplace at the time of the conclusion of the lease is that of the transfer of property tax to the lessee, such…

 

Immobilier commercial

Claim affecting the commercial premises, damage suffered and action for compensation

Damage, disorders, defects, damage, deterioration, or non-conformities may be revealed as soon as the lease is taken or after several years of use, disturbing enjoyment, disrupting the activity and thus causing harm. Why act? The first reflex of the lessee must be to provide evidence of the…

 

Produits, Consommation, Publicité

Online advertising verification: precautionary measures against META

The Competition Authority (ADLC), seized in October 2022 by the company Adloox SAS of practices implemented by the meta companies Platforms Inc, Meta Platforms Ireland Ltd and Facebook France in the advertising verification on the internet, pronounced provisional measures against Meta on 4 M…

 

Produits, Consommation, Publicité

Legality of comparative advertising according to the Court of Cassation

The lawfulness of a comparative price advertisement carried out by a hypermarket under the Carrefour brand concerning the prices charged by two competing hypermarkets under the Leclerc brand was examined by the Court of Cassation in a judgment delivered on 22 March 2023. In this case, Carre…

 

Produits, Consommation, Publicité

Legality of the trader's sales claims

In order to promote its products or services, the professional may in particular value their qualities, their compositions, their manufacturing methods or their effects. However, these commercial claims can be qualified as deceptive commercial practices. Advertising is defined by European …

 

Produits, Consommation, Publicité

Advertising for alcoholic beverages: is the “Cuba made me” campaign illegal?

A judgment rendered by the Paris Court of Appeal in a dispute between an association fighting alcoholism and a company selling alcoholic products on two advertisements for a famous brand of rum makes it possible to recall the criteria for the legality of an advertisement for alcoholic bevera…

 

Produits, Consommation, Publicité

Price reductions: the regulation of sales

Sale operations, liquidations, factory store sales or unpacking sales all tend to offer consumers a range of products at reduced prices. However, each of these sales transactions has a very distinct legal regime, the main obligations of which we present to you. a) The legal definition of …

 

Réseaux de distribution, Concurrence

Franchisor Responsibility and/vs Franchisee Duties

The Paris Court of Appeal recalls the duty of the franchisee, as an independent trader, to provide information during the pre-contractual phase and refuses to cancel the franchise agreement concluded in the absence of transmission of a dip. The Paris Court of Appeal, in a decision of 9 Nove…

 

Réseaux de distribution, Concurrence

Abuse of Dominant Position Attributed to the Network Head - Criteria

The CJEU specifies the conditions under which a head end may be sanctioned under Article 102 TFEU for acts physically committed by its distributors and rules on the competitor’s test as effective in the presence of exclusivity clauses. Referral of a question by the Italian Council of …