Last December, in the recently-released Case 5597/2007, a Barcelona criminal court ordered the blocking of a website operated from outside the European Union as a precautionary measure. The proceedings concerned the owner of a well-known registered trade mark filed suit, who was suing the owners of a Chinese website which traded in counterfeit products. The blocking request prima facie fell under Article 129 of the Spanish Criminal Code which provides that, in addition to a penalty, certain additional measures may be taken. These include the suspension and even the closure of an infringer's company, business or trading activities. Recognising that the blocking of the website was an analogous act, the court stll faced the problem that this relief could not be given without a full hearing. Accordingly the court instead applied the Spanish implementation of Directive 31/2000 (the E-Commerce Directive), Article 8 of which provides for the possibility of restricting the provision of internet services where a criminal investigation is taking place or the protection of consumers or users is jeopardized. The court therefore ordered the blocking of the website issue until the conclusion of the investigative phase of the proceedings [source: Marta Giménez-Zapiola (Grau & Angulo, Barcelona), writing in World Trademark Report].