The EU Court of Justice upholds the Commission’s decision finding that unilateral measures can prove anticompetitive agreement in the absence of written records (Sandoz)

Case C-277/87 Sandoz prodotti farmaceutici SpA v Commission of the European Communities* 1. The systematic dispatching by a supplier to his customers of invoices bearing the words 'Export prohibited' constitutes an agreement prohibited by Article 85(1) of the Treaty, and not unilateral conduct, when it forms part of a set of continuous business relations governed by a general