The International Aspects of Private Enforcement after the Directive 2014/104/EU : Gaps in the EU System and Competition between National Laws?
Directive 2014/104, i.e. the ’Damages Directive’, is currently being transposed into national law. The aim of this directive is admittedly not to solve the issues of private international law arising from actions for damages; however, its provisions will likely increase these issues in the context of cross-border actions. The recent rulings of the Court of Justice, far from settling this question, only emphasize these difficulties