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Subject: Public Comments

Dear members of the LegalDocumentML

As Chair of the ELI Task Force, and on behalf of

·         Denmark

·         Finland

·         Ireland

·         Luxembourg

·         Publications Office of the European Union (comments also sent individually)

·         United-Kingdom (comments also sent individually)

·         France

we would like to send the following comments.

Constructing a universal naming convention, given the differences in national legal systems, is very complex and does not cover all national legislation cases and especially hinder existing naming conventions.

In line with the principle of proportionality and the principle of decentralization, each country and company should continue to operate its own national Official Journals, Legal Gazettes or legal databases in the way they prefer. We should therefore carefully consider not to impose a naming convention in order to respect the legal and constitutional differences between countries, and authorize on equal footing other naming conventions, e.g. URN-Lex, ECLI, ELI etc.

This flexibility would help the implementation of the revised version of AKN.

We therefore fully support the comments of the Office of Publications of the EU sent earlier by email.


Best regards,




John Dann


Ministère d'État

Service central de législation

43, bd Roosevelt . L-2450 Luxembourg

Tél. (+352) 247-82961 . Fax (+352) 46 74 58
E-mail : john.dann@scl.etat.lu





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