The Court of Justice of the European Union (CJEU) tackled these questions in its judgment of 9 July 2026 in Anne Frank Fonds v Anne Frank Stichting and Others (Case C-788/24). Its answer is both technologically pragmatic and legally significant: effective geo-blocking can define and restrict the group of internet users to whom an online work is communicated, and the mere possibility that such restrictions may be circumvented using a VPN does not necessarily result in a communication to the public in the protected territory.
Source: Copyright without digital borders? The CJEU on geo-blocking, VPNs and territoriality