38Thus, the Court of Justice has previously acknowledged the existence of such general presumptions in respect of, inter alia, documents in the administrative file relating to a procedure for reviewing State aid (see, to that effect, judgments of 29 June 2010, Commission v Technische Glaswerke Ilmenau, C‑139/07 P, EU:C:2010:376, paragraph 61, and of 14 July 2016, Sea Handling v Commission, C‑271/15 P, not published, EU:C:2016:557, paragraph 36), documents exchanged between the Commission and the notifying parties or third parties during merger control proceedings (see, to that effect, judgments of 28 June 2012, Commission v Éditions Odile Jacob, C‑404/10 P, EU:C:2012:393, paragraph 123, and of 28 June 2012, Commission v Agrofert Holding, C‑477/10 P, EU:C:2012:394, paragraph 64), or documents in a file relating to proceedings under Article 101 TFEU (see, to that effect, judgment of 27 February 2014, Commission v EnBW, C‑365/12 P, EU:C:2014:112, paragraph 93). The General Court has also recognised the existence of a general presumption in respect of, inter alia, documents in the administrative file for a procedure relating to an abuse of a dominant position (judgment of 28 March 2017, Deutsche Telekom v Commission, T‑210/15, EU:T:2017:224, paragraph 45).
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