27As a preliminary point, it should be recalled that Article 2(d) of the Unfair Commercial Practices Directive gives a particularly wide definition of ‘commercial practices’: ‘any act, omission, course of conduct or representation, commercial communication including advertising and marketing, by a trader, directly connected with the promotion, sale or supply of a product to consumers’ (see, inter alia, Joined Cases C-261/07 and C-299/07 VTB-VAB and Galatea [2009] ECR I-2949, paragraph 49; Case C-304/08 Plus Warenhandelsgesellschaft [2010] ECR I-217, paragraph 36; and Case C-540/08 Mediaprint Zeitungs- und Zeitschriftenverlag [2010] ECR I-10909, paragraph 17). In addition, under Article 2(c) of the directive, the term ‘product’, within the meaning of that directive, also includes services.
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