On 14 April 2021, the Court of Appeal dismissed an appeal by Infineon and Micron against a High Court judgment finding that an action for damages, allegedly suffered as a result of the DRAM cartel, was not time-barred (see UK Competition Newsletter, April – May 2020). The Court of Appeal upheld the High Court’s decision that, for limitation purposes, a claimant in liquidation could not be expected to have the same knowledge as a trading company at the time the cartel investigation opened. The Court took the view that nothing in section 32 of the Limitation Act 1980 requires a claimant to be treated as if it were in business at the time the wrongdoing emerged.