Mr. Dermott Jewell:

I will explain the dynamic behind it. The approach that has been taken in other member states involves trying to understand the potential costs of funding a group action or collective action through the courts, usually the equivalent of our High Court. Several methods have been flagged. One method involves taking an initial case on an opt-out basis, which means that they take a case to a lower court, present it and see what comes from it. Another method involves taking a case on behalf of a pocketful of their members and seeing what the position is. This is done to inform their legal advisers on how to proceed, what the timeframe and the costs are potentially going to be, and the depths to which they will have to invest to take a full class action, certainly if it is going to be a cross-border action.