28.
Google LLC filed its written submissions dated 3 October 2019.
29.
The Appellant filed a statement of response dated October 2019
(without a specific date) to reply to the statement of the Respondent and
the written submissions of Google LLC.
30.
The Board has considered the grounds of appeal which at the hearing
condescend to the issues set out hereinbelow, all the written submissions
of the Parties and the oral submissions they made at the appeal hearing.
The Board does not propose to set out all the submissions and arguments
on the issues raised in detail. At the hearing upon the request of the Board
,
Counsel for Google LLC prepared a summary of the positions/stances of
the parties in relation to the main issues of the appeal ("the Summary"),
to which the Respondent agrees and the Appellant only wants to add some
references of his case.
Attached herewith the Summary with the
Appellant's added references in red. With the assistance of the Summary
it suffices for the Board to set out, in the course of analysis and reasons of
the Board herein, the more relevant and important submissions of the
parties.
D Issues
.
31.
Having considered the grounds of appeal and the respective
submissions of the parties, as agreed by the parties and set out in the
Summary, the following main issues fall to be resolved by the Board:
a
.
What is the territorial scope of the Ordinance? This is purely a
question of law.
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