On 3 May 2012, the French Supreme Court ruled that all written communications between an external lawyer and its client are covered by legal professional privilege. This protection applies irrespective of the matter covered by the written communication, even if it does not deal with the client’s rights of defence. This ruling was made in connection with dawn raids in tax matters, but should also apply to competition law dawn raids. It is worth noting that this ruling grants undertakings greater protection than that afforded by the Court of Justice of the European Union in its Azko judgment dated 14 September 2010, where the Court stated that legal privilege only applies to communications with external lawyers which relate to the client’s rights of defence.