"The greatest risk therefore lies with Germany's consumer protection
associations such as the VZBV which have the benefit of extensive
financial means and which have already repeatedly targeted the video
gaming industry for youth protection and e-commerce matters.
"The
new guideline provides a strong argument in court on how the JMStV
advertisement restrictions must be interpreted and therefore a strong
basis for potential cease and desist claims/injunctions."
I'm not sure if it's unusual, but German law has this quirk where certain illegal actions can effectively be for-profit enforced by private actors.
The company that gets sued will foot the bill if they lose the suit, otherwise the consumer protection association pays.
It was a bit of a problem when law companies used this to mass-C&D people over web publishing mistakes and smaller copyright infringement, but I think that's settled down a little.
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