Akzo Nobel and Ackros Chemicals have appealed a Court of First Instance (CFI) judgment upholding a Commission decision that documents seized during an investigation are not protected by legal professional privilege. The set of documents in dispute included: (i) handwritten notes by Akros’s general manager of discussions with employees used to prepare a memo for a superior for the purpose of obtaining external legal advice; and (ii) two emails between Akros’s general manager and Akzo’s in-house lawyer. The CFI acknowledged that preparatory documents could be privileged so long as their main purpose was to obtain external legal advice and confirmed that communications between in-house counsel and internal clients are not privileged in relation to Commission competition investigations.