21It should also be pointed out that, in its case-law relating to Article 16(1)(a) of the Brussels Convention – which, according to recital 19 of Regulation No 44/2001, also applies for the purposes of construing Article 22(1) of that regulation - the Court has held that that provision of the Brussels Convention must be interpreted as meaning that the exclusive jurisdiction of the courts of the Contracting State in which the property is situated does not encompass all actions concerning rights in rem in immovable property, but only those which both come within the scope of the convention and are actions which seek to determine the extent, content, ownership or possession of immovable property or the existence of other rights in rem therein and to provide the holders of those rights with protection for the powers which attach to their interest (see, inter alia, Case C-115/88 Reichert and Kockler [1990] ECR I-27, paragraph 11, and ČEZ, paragraph 30).
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