In summary, Kapatens makes the following assessment with respect to the sections in the report on which Kapatens finds reason to provide comments.

A collective redress regime that provides for automatic opt-out should be introduced as soon as possible. Kapatens opposes the proposal regarding distribution of funds not claimed by group members and suggests that it should be possible to distribute such funds to a third-party funder. Kapatens holds that the language “unduly” should be added to the proposed provision that a third-party funder may not influence the procedural decisions of a qualified entity, to the detriment of the common interests of the group members. Kapatens agrees with the proposal that qualified entities should be able to request the production of documents regarding the identity of potential group members.

You can read Kapatens’ comments on the Report (in Swedish) here