Since the early 1990s many discussions have focused on the possibility of a national judge issuing injunctions for infringement in another country: cross-border injunctions. This practice, starting in The Netherlands, was effectively halted with the decisions GAT v LUK (C-4/03) and Primus v Roche (C-539/03) at the Court of Justice of the EU. However, in cases where validity of the patent is not the issue, the CJ recognised that cross-border injunctions were still possible (Duijnstee v Goderbauer (C-288/82)).