The Wintersteiger decision takes matters one step further by applying the principles developed with respect to an infringement of personality rights to infringements of trademarks. At least there is some foreseeability regarding a person’s ‘centre of interest’ (despite the legimitate doubts which you’ve raised). With respect to trademark infringement, competitors on the market may have a hard time identifying potential trademarks in all 27 Member States. In terms of conflicting national trade marks protected in different Member States (cf. the German Federal Court of Justice’s ‘Hotel Maritime’-decision), the Court of Justice’s approach allows the courts of the country in which the claimant’s right is registered to decide upon internet-wide injunctions. That certainly is some advantage for the claimant. On the other hand, if the supposed infringer had received a warning letter and then breached his undertaking not to further infringe the trademark, Besix would apply.