First report: Important developments and substantive issues, March-July 2016 2016, para. 37b
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[Furthermore, the draft German law raises a whole plethora of other concerns:] Mass surveillance: mass and targeted surveillance of extraterritorial communications between non-German citizens would be effectively authorized in cases where the communication interception is carried out in Germany. While targeted surveillance in line with the criteria outlined in Zakharov v. Russia is of less concern, mass surveillance remains a cause for grave concern and prima facie runs counter to the standards established in European law;