—

declare the action admissible;

—

annul the decision in its entirety or, in the alternative, in so far as it concerns the applicant; (1)

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in the alternative, annul Article 2 of the decision in so far as it requires the recovery of the amounts of aid at issue in total or, in the alternative, in so far as it concerns the applicant; and

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order the Commission to pay the costs.

1.

First plea in law, alleging misinterpretation and lack of reasoning on the part of the Commission concerning the existence of State aid: the criteria of economic advantage, selectivity and distortion of competition are not met.

2.

Second plea in law, claiming that the contested measures constitute compatible aid within the meaning of Article 107(2)(b) TFEU.

3.

Third plea in law, alleging infringement of the principles of sound administration, of the right to be heard and of the obligation to state reasons for the decision, and infringement of Article 41 of the Charter of Fundamental Rights of the European Union.

4.

Fourth plea in law, alleging infringement of Article 14(1) of Regulation (EC) No 659/1999 (2) and Article 16(1) of Regulation (EU) 2015/1589, (3) and that the decision was adopted in breach of the principles of legal certainty and legitimate expectations.

5.

Fifth plea in law, alleging that the decision was adopted in breach of the principle of proportionality.