On February 28, 2018, the DCA significantly increased the fine that the FCO had imposed on drug store chain Dirk Rossmann GmbH (“Rossmann”) nearly sixfold.[1] However, at the time, the DCA only issued a press release which left ample room for speculation about the precise reasoning behind the court’s decision to increase the fine. The DCA now published a non- confidential version of its judgment that provides further insights.