43With respect, next, to Article 20 TFEU, the Court has previously had occasion to hold that the situation of a Union citizen who, like the children of Finnish nationality concerned in the main proceedings, has not made use of the right of freedom of movement cannot for that reason alone be assimilated to a purely internal situation, that is, a situation which has no factor linking it with any of the situations governed by European Union law (see Ruiz Zambrano; Case C-434/09 McCarthy [2011] ECR I-3375, paragraph 46; and Dereci and Others, paragraph 61).
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