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annul the European Central Bank (ECB) decisions of 23 February 2018 that the applicant and ABLV Bank Luxembourg, SA are failing or likely to fail; and

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order the defendant to pay the costs.

1.

First plea in law, alleging that the ECB’s assessment of the ‘failing or likely to fail’ criterion’ in respect of the applicant and its subsidiary ABLV Bank Luxembourg was erroneous and deficient in a number of regards.

2.

Second plea in law, alleging that the ECB violated the right to be heard and other procedural rights of the applicant.

3.

Third plea in law, alleging that the ECB violated the applicant’s right to an appropriately reasoned decision.

4.

Fourth plea in law, alleging that the ECB failed to examine and appraise carefully and impartially all the relevant aspects of the individual case.

5.

Fifth plea in law, alleging violation of the principle of proportionality.

6.

Sixth plea in law, alleging that the ECB violated the principle of equal treatment.

7.

Seventh plea in law, alleging that the ECB violated the right of property and the freedom to conduct a business.

8.

Eighth plea in law, alleging that the ECB violated the nemo auditur principle.

9.

Ninth plea in law, alleging that the ECB committed a détournement de pouvoir.

10.

Tenth plea in law, alleging violation of the applicant’s right pursuant to Article 41 of the Charter on Fundamental Rights because of a failure to ensure the handling of the applicant’s affairs by the relevant institutions and bodies of the Union.