20As the Court observed at paragraph 49 in Commission v France, Article 14(3) of Regulation No 659/1999 reflects the requirements of the principle of effectiveness laid down previously by case-law (see Case 94/87 Commission v Germany [1989] ECR 175, paragraph 12; Case C-24/95 Alcan Deutschland [1997] ECR I-1591, paragraph 24; and Case C-209/00 Commission v Germany [2002] ECR I-11695, paragraphs 32 to 34); that case-law is therefore relevant to the application of that provision.
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