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L'Oreal started legal action in France, Belgium, Germany, Britain and Spain in September 2007, alleging the online auctioneer did not do enough to combat the sale of counterfeits.
None of the other courts have ruled on the case yet.
The Belgian court ruled that eBay was not obliged to take action to fight counterfeiting, but eBay spokeswoman Sravanthi Agrawal stressed that the company cooperated with rights owners to tackle the sale of fake goods. She added that the company clamped down on all cases of counterfeiting notified to it by the firms concerned, even though it did not have a legal obligation to do so.
L'Oreal said in a statement it would appeal against the decision.