On March 19, 2026, the Court of Justice of the European Union (CJEU) delivered its judgment in Case C‑526/24 (Brillen Rottler), addressing a preliminary reference from the District Court Arnsberg (Germany). The case involves a phenomenon colloquially known as “GDPR hopping” — where individuals sign up for services (such as newsletters), promptly submit data access requests under Article 15 GDPR, and then claim non-material damages under Article 82(1) GDPR when the controller fails to comply or responds inadequately.

Click here to read the full GT Alert.

Tags: CJEU, European Court of Justice, European Union, GDPR, GT Insight
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Photo of Dr. Philip Radlanski Dr. Philip Radlanski

Philip Radlanski is a Local Partner in the IP & Technology Practice Group. He advises clients ranging from early-stage start-ups to large corporations on privacy and cybersecurity issues. His work focuses on complex and innovative data-heavy projects, often with cross-border aspects. He also

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Philip Radlanski is a Local Partner in the IP & Technology Practice Group. He advises clients ranging from early-stage start-ups to large corporations on privacy and cybersecurity issues. His work focuses on complex and innovative data-heavy projects, often with cross-border aspects. He also assists with addressing cybersecurity issues, including data breach incident management and response. He gained strong recognition throughout Europe for his representation in the first German trial against a GDPR fine, in which he was able to achieve a reduction of the multimillion-euro fine by more than 90 percent.

Philip is known for his pragmatic approach, which he was able to further refine through several months of secondments to the legal departments of a leading German internet service provider and an internationally operating online marketplace for food delivery. A further one-year secondment to the Global Privacy & Data Security Group of an international law firm in New York shaped Philip’s understanding of the U.S. market and U.S. clients.

Prior to practicing as an attorney, Philip worked as a research assistant at the University of Regensburg, Germany, and as a visiting tutor at King’s College London, UK. He also worked with the German Federal Film Board, the cybercrime division of the Berlin District Attorney’s Office, and for different international law firms in Berlin, New York, and Sydney.

He is a member of the German Association for the Protection of Intellectual Property and Copyright (GRUR), the International Technology Law Association (ITechLaw), and the Bauhaus Archive.

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Photo of Carsten A. Kociok Carsten A. Kociok

Carsten Kociok is a partner in the Technology, Financial Services and Data Privacy Practice in Berlin and Co-Head of Greenberg Traurig’s global Fintech Group. He advises national and international clients across all industries, including financial services, information technology, artificial intelligence, ecommerce, media, health

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Carsten Kociok is a partner in the Technology, Financial Services and Data Privacy Practice in Berlin and Co-Head of Greenberg Traurig’s global Fintech Group. He advises national and international clients across all industries, including financial services, information technology, artificial intelligence, ecommerce, media, health care, telecoms, retail and real estate, on a wide variety of complex commercial and regulatory matters.

Carsten is a leading technology lawyer, ranked consistently in Band 1 for Fintech Legal in Germany since 2020. He has in-depth and wide-ranging experience in the areas of privacy and cybersecurity, payments law, financial services, e-money products, blockchain technology, and financial and banking regulation, as well as in artificial intelligence regulation – including compliance with the EU AI Act – and the integration of AI technologies into existing software systems.

Carsten regularly assists clients in licensing projects and audit proceedings with financial regulators and advises on the contractual and regulatory aspects of developing, implementing and operating financial technology products and transactions.

On the data privacy side, Carsten counsels clients on complex data-driven business models and regulatory matters, including on international data transfers, data privacy compliance, monetization of data, artificial intelligence, litigation, cybersecurity and data breach response.

Carsten regularly lectures and publishes on various FinTech and data privacy topics. Prior to joining the firm, Carsten worked at Olswang Germany for eight years and in the Capital Transaction Practice Group of an international law firm in New York.

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Photo of Dr. Jannis P. Dietrich Dr. Jannis P. Dietrich

Jannis Dietrich advises national and international companies on issues concerning the internet, technology, data protection, digitization and litigation. He combines his legal experience with his technical knowledge as a certified electronic technician for IT systems and consequently is now skilled in the interface…

Jannis Dietrich advises national and international companies on issues concerning the internet, technology, data protection, digitization and litigation. He combines his legal experience with his technical knowledge as a certified electronic technician for IT systems and consequently is now skilled in the interface of law and technology. The key areas of his practice are IT, copyright and licensing law, advice on digital and blockchain-based business models, as well as data protection, competition and consumer protection law.

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