The private enforcement of competition law has been one of the most dynamic areas of law in the UK.1 This has in large part been due to the development of specific procedural rules designed to facilitate the private enforcement of the competition rules. Those procedural rules provide a framework around which a body of case law has begun to develop. Inevitably, in a developing area of law, many of the cases before the courts involve the consideration of preliminary issues such as jurisdiction and limitation periods. A number of first instance decisions have been reviewed by the higher courts. As a consequence, much of the case law considered below relates to interlocutory matters, not to substantive issues.