The Court of First Instance has upheld a Commission decision that documents drawn up by in-house lawyers are not covered by legal professional privilege (LLP) under EU law, even where in-house lawyers are governed by obligations imposed by an independent body, such as the Law Society. In joined cases T-125/03 and T-253/03 the applicants, Akzo Nobel Chemicals Limited (Akzo), had been under investigation by the Commission for suspected competition infringements of Articles 81 and 82 EC. During the investigation, the Commission seized documents, which Akzo claimed were protected by LLP since they were drawn up by their in-house lawyer (a member of the Netherlands Bar) and subsequently discussed with independent external lawyers. The Commission argued that the documents were not protected by LLP because they were merely internal documents, which were not created for the purpose of defending the alleged infringements. However, the CFI maintained the position that communications with in-house lawyers are not protected by LLP and therefore have to be released to the Commission during a competition investigation.