Pammer and Hotel Alpenhof - ECJ decision creates further uncertainty about when e-businesses "direct activities" to a consumer's state under the Brussels i Regulation

The European Court of Justice's recent judgement in the joined cases C-585/08 and C-144/09 will have substantial long-term implications for European e-businesses and e-consumers trading across borders. The key question considered was whether the fact that a website can be consulted on the Internet in the Member State of the consumer's domicile is sufficient to justify a finding that commercial or professional activities are being directed to that Member State within the meaning of Article 15(1)(c) of the Brussels I Regulation.