Diffusion de contenus illicites par internet : compétence internationale

  • Posted by Loïc Panhaleux
  • On 4 décembre 2014
  • 727 Comments
  • compétence internationale, internet, règlement 1215/2012, responsabilité

La diffusion de contenus illicites par internet peut poser des questions de compétence internationale.

Technologie
Lorsque des contenus illicites sont diffusés sur internet, comme par exemple des photographies, des vidéos ou des musiques contrefaites, des images ou articles portant atteintes à la vie privée, voire constituant des diffamations, la question se pose de savoir quelle juridiction est compétente pour réparer le dommage qui en résulte. Lorsque cette diffusion faite à partir d’un Etat est accessible dans de nombreux autres Etats, cela entraîne des questions de compétence internationale.

Pour déterminer cette compétence, il convient d’appliquer le Règlement (UE) No 1215/2012 DU PARLEMENT EUROPÉEN ET DU CONSEIL du 12 décembre 2012 concernant la compétence judiciaire, la reconnaissance et l’exécution des décisions en matière civile et commerciale à compter du 10 janvier 2015 (article 81). Ce Règlement abroge le Règlement n° 44/2001 du 22 décembre 2000 (article 80).

Son article 66 contient des dispositions transitoires, le premier paragraphe disposant que, « Le présent règlement n’est applicable qu’aux actions judiciaires intentées, aux actes authentiques dressés ou enregistrés formellement et aux transactions judiciaires approuvées ou conclues à compter du 10 janvier 2015. ». Ce Règlement s’applique dans tous les Etats membres. Mais, conformément à son article 67, il « ne préjuge pas de l’application des dispositions qui, dans des matières particulières, règlent la compétence judiciaire, la reconnaissance et l’exécution des décisions et qui sont contenues dans les actes de l’Union ou dans les législations nationales harmonisées en exécution de ces actes. ». Il existe bien des textes spécifiques dans certains domaines, comme en matière de droit d’auteur. Aucun, à notre connaissance ne contient cependant des règles de compétence. Cela ne saurait signifier que l’existence de telles normes est totalement indifférente quant à la détermination de la compétence dans le cadre du règlement n°1215/2012.

Il convient par ailleurs de tenir compte d’éventuelles conventions internationales. Si le Règlement prévaut sur les conventions conclues entre les Etats membres, qu’elles soient bilatérales ou unilatérales (v. article 69), cela ne vaut que pour les matières auxquelles le Règlement n’est applicable (article 70). En outre, le Règlement ne prévaut pas sur les conventions auxquelles les Etats membres sont parties (article 71 § 1). Dans ce cas, aux termes du § 2 1 « En vue d’assurer son interprétation uniforme, le paragraphe 1 est appliqué de la manière suivante: a)le présent règlement ne fait pas obstacle à ce qu’une juridiction d’un État membre partie à une convention relative à une matière particulière puisse fonder sa compétence sur une telle convention, même si le défendeur est domicilié sur le territoire d’un autre État membre non partie à une telle convention. La juridiction saisie applique, en tout cas, l’article 28 du présent règlement ». Mais là encore, dans le domaine de la responsabilité civile du fait de diffusions sur internet, aucune convention internationale ne paraît a priori pouvoir être appliquée. Il reste à préciser que l’article 73 prévoit que la Convention de Lugano de 2007 est applicable de même que les conventions et accords bilatéraux conclus entre un État tiers et un État membre avant la date d’entrée en vigueur du règlement (CE) no 44/2001 qui portent sur des matières régies par le présent règlement.

Le domaine d’application du Règlement reste donc très large. La compétence générale ou de principe est affirmée par l’article 4 § 1 : Sont compétentes les juridictions de l’Etat membre du domicile du défendeur. Si le défendeur n’est pas domicilié sur le territoire d’un Etat membre, la compétence est alors déterminée selon la loi de chaque Etat membre (article 6 § 1). Nous ne considérons ici que la première hypothèse qui conduit à s’interroger sur la mise en œuvre des compétences spéciales prévues à l’article 7 du règlement en ses dispositions relatives à la responsabilité extracontractuelle. En premier lieu, l’article 7 § 2 dispose qu’une personne domiciliée sur le territoire d’un État membre peut être attraite, dans un autre État membre: « en matière délictuelle ou quasi délictuelle, devant le tribunal du lieu où le fait dommageable s’est produit ou risque de se produire ». En second lieu, l’article 7 § 3 prévoit que « s’il s’agit d’une action en réparation de dommage ou d’une action en restitution fondées sur une infraction », ce défendeur peut être attrait « devant la juridiction saisie de l’action publique, dans la mesure où, selon sa loi, cette juridiction peut connaître de l’action civile ».

Si le second ne semble pas poser de difficultés puisque le tribunal compétent au pénal juge du civil, la comment faut-il interpréter le premier de ces textes en cas de délits complexes, c’est-à-dire de délits dont les éléments sont répartis sur plusieurs Etats membres, ce qui est le cas d’une diffusion sur internet, opérée sur un Etat mais dont les répercussions peuvent être ressenties au-delà de l’Etat du domicile de la victime ?
La jurisprudence la plus récente de la Cour de Justice de l’Union européenne montre combien la réponse à cette question est délicate.
Avant même de voir l’interprétation qui est faite par cette Cour des dispositions précitées, il faut rappeler que cette interprétation est autonome, autrement dit qu’elle ne relève que de la Cour de Justice et non des juridictions nationales. Il en va tout d’abord ainsi de la matière délictuelle.(CJCE, 27 sept. 1988, aff. 189/87, Kalfelis). La Cour de justice la définit comme la demande relative à la responsabilité d’un défendeur qui ne se rattache pas à la matière contractuelle (Ibid). Or, la matière contractuelle est définie comme un lien contractuel librement assumé entre parties à un contrat (CJCE, 17 juin 1992, Rec. CJCE, I 3990).

Quant à la notion de fait dommageable, elle a été interprétée de manière large par la Cour de Justice. En effet, le lieu où le fait dommageable s’est produit peut être à la fois le lieu où le dommage est survenu et celui de l’évènement causal. Lorsqu’ils sont distincts, le défendeur peut être attrait au choix du demandeur devant le tribunal de l’un de ces lieux.

La Cour de Justice a notamment jugé que lorsque le fait dommageable s’est produit en plusieurs endroits (ex : diffamation par voie de presse), la victime peut intenter son action en réparation, soit devant les juridictions du lieu d’établissement de l’auteur de l’acte, compétentes pour réparer l’intégralité du dommage, soit devant les juridictions de chaque Etat où le fait dommageable s’est produit, seulement compétentes pour connaître du dommage causé dans l’État de la juridiction saisie (CJCE, 7 mars 1995, Fiona Shevill, C. 68/93).
Toutefois, la Cour avait ensuite considéré que la notion de « lieu où le fait dommageable s’est produit ne saurait être interprétée de façon extensive au point d’englober tout lieu où peuvent être ressenties les conséquences préjudiciables d’un fait ayant causé un dommage effectivement survenu dans un autre lieu. D’une part, cette interprétation ferait dépendre la détermination de la juridiction compétente de circonstances incertaines et serait par conséquent contraire au renforcement de la protection juridique des personnes établies dans la Communauté qui, en permettant à la fois au demandeur d’identifier facilement la juridiction qu’il peut saisir et au défendeur de prévoir raisonnablement celle devant laquelle il peut être attrait, constitue un des objectifs de la convention. D’autre part, elle serait susceptible le plus souvent de reconnaître la compétence des tribunaux du domicile du demandeur, compétence pour laquelle la convention n’apparaît pas favorable en dehors des cas qu’elle prévoit expressément (Arrêt du 10 juin 2004, Kronhofer (C-168/02, Rec._p._I-6009) (cf. points 19-21 et disp.) ».

Mais la CJUE a ensuite décidé que « L’article 5, point 3, du règlement (CE) no 44/2001 du Conseil, du 22 décembre 2000, concernant la compétence judiciaire, la reconnaissance et l’exécution des décisions en matière civile et commerciale, doit être interprété en ce sens que, en cas d’atteinte alléguée aux droits de la personnalité au moyen de contenus mis en ligne sur un site Internet, la personne qui s’estime lésée a la faculté de saisir d’une action en responsabilité, au titre de l’intégralité du dommage causé, soit les juridictions de l’État membre du lieu d’établissement de l’émetteur de ces contenus, soit les juridictions de l’État membre dans lequel se trouve le centre de ses intérêts. Cette personne peut également, en lieu et place d’une action en responsabilité au titre de l’intégralité du dommage causé, introduire son action devant les juridictions de chaque État membre sur le territoire duquel un contenu mis en ligne est accessible ou l’a été. Celles-ci sont compétentes pour connaître du seul dommage causé sur le territoire de l’État membre de la juridiction saisie. » (CJUE, 25 octobre 2011, Olivier Martinez et Robert Martinez contre MGN Limited, C-161/10, v. ég. CJUE, 25 octobre 2011, E-Date Advertising, C 509/09).
En vertu de cette jurisprudence, la victime disposait d’un choix supplémentaire. Pour demander réparation de son entier préjudice, au-delà de la possibilité d’agir devant les juridictions de l’Etat membre du défendeur en vertu de l’article 2 (article 4 en vertu du Règlement 1215/2012), elle peut agir devant les juridictions de l’Etat membre dans lequel se trouve le centre de ses intérêts, soit le plus souvent son propre domicile. Elle conserve évidemment la possibilité d’agir devant les juridictions de chaque Etat membre où le contenu mis en ligne est accessible ou l’a été.
Les arrêts les plus récents ont apporté de nouveaux éclaircissements sur cette question.

Tout d’abord, dans un arrêt du 25 octobre 2012, la Cour a estimé qu’il fallait s’interroger sur l’identification de l’un des points de rattachement reconnus par la jurisprudence devant permettre d’établir la compétence de la juridiction objectivement la mieux placée pour apprécier si les éléments constitutifs de la responsabilité de la personne attraite sont réunis (arrêt du 16 mai 2013, Melzer, C 228/11) et que ne peut être valablement saisie que la juridiction dans le ressort duquel se situe le point de rattachement pertinent (voir, en ce sens, arrêt du 25 octobre 2012, Folien Fischer et Fofitec, C 133/11, point 52).

Ensuite, dans l’arrêt Wintersteiger, (CJUE, 19 avril 2012, Wintersteiger, C 523/10), la Cour a apporté d’utiles précisions. Elle a tout d’abord considéré que le lieu de la matérialisation du dommage pouvait varier en fonction de la nature du droit prétendument violé (voir, en ce sens, arrêt Wintersteiger, précité, points 21 à 24). Puis elle a précisé que le risque qu’un dommage se matérialise dans un État membre déterminé est subordonné à ce que le droit dont la violation est alléguée soit protégé dans cet État membre (voir arrêt Wintersteiger, précité, point 25). Enfin, elle a ajouté que l’identification du lieu de la matérialisation du dommage aux fins d’attribuer à une juridiction la compétence pour connaître d’une allégation d’atteinte en matière délictuelle ou quasi délictuelle dépend également du point de savoir quelle juridiction est la mieux à même d’apprécier le bien-fondé de l’atteinte alléguée (Wintersteiger, point 27).
En conséquence, la Cour a décidé de distinguer, pour les besoins de l’identification du lieu de la matérialisation d’un dommage prétendument causé au moyen d’Internet, entre les atteintes aux droits de la personnalité et celles à un droit de la propriété intellectuelle et industrielle. En matière de marques, elle a ainsi jugé que l’allégation d’une atteinte à un droit de la propriété intellectuelle et industrielle, dont la protection accordée par un acte d’enregistrement, est limitée au territoire de l’État membre d’enregistrement, doit être portée devant les juridictions de celui-ci car ce seraient les juridictions de l’État membre d’enregistrement qui sont les mieux à même d’évaluer s’il est effectivement porté atteinte au droit en cause. (Wintersteiger, points 25 et 28).

Les droits d’auteur ne sont pas soumis à enregistrement. Fallait-il dès lors considérer que la jurisprudence Wintersteiger devait prévaloir ou au contraire appliquer la jurisprudence Martinez ? Dans un arrêt du 3 octobre 2013, la Cour répond à cette interrogation : « L’article 5, point 3, du règlement (CE) nº 44/2001 du Conseil, du 22 décembre 2000, concernant la compétence judiciaire, la reconnaissance et l’exécution de décisions en matière civile et commerciale, doit être interprété en ce sens que, en cas d’atteinte alléguée aux droits patrimoniaux d’auteur garantis par l’État membre de la juridiction saisie, celle-ci est compétente pour connaître d’une action en responsabilité introduite par l’auteur d’une œuvre à l’encontre d’une société établie dans un autre État membre et ayant, dans celui-ci, reproduit ladite œuvre sur un support matériel qui est ensuite vendu par des sociétés établies dans un troisième État membre, par l’intermédiaire d’un site Internet accessible également dans le ressort de la juridiction saisie. Cette juridiction n’est compétente que pour connaître du seul dommage causé sur le territoire de l’État membre dont elle relève. »

Cette solution peut s’expliquer par le caractère territorial de la protection accordée au titre du droit de propriété intellectuelle, même s’il convient de préciser qu’une harmonisation est intervenue en matière de droit d’auteur du fait de la directive 2001/29/CE du Parlement européen et du Conseil du 22 mai 2001 sur l’harmonisation de certains aspects du droit d’auteur et des droits voisins dans la société de l’information.

La solution devrait être logiquement appliquée à une autre affaire (Pez Hedjuck contre EnergieAgentur.NRW Gmbh, affaire C-441/13). La Cour a en effet été saisie à titre préjudiciel d’une demande d’interprétation de l’article 5 point 3) en cas d’atteinte aux droits voisins du droit d’auteur garantis par l’Etat membre de la juridiction saisie. La question a été posée de savoir si cette juridiction peut être compétente pour connaître d’une action en responsabilité pour l’atteinte à ces droits du fait de la mise en ligne de photographies protégées sur un site internet accessible dans son ressort.

Mais toutes les incertitudes ne sont pas levées comme le prouve une autre demande faite à la Cour relative à l’indemnisation d’un préjudice subi du fait d’ententes illicites : « faut-il interpréter l’article 5, point 3, du règlement [Bruxelles I] en ce sens que, lorsque des défendeurs établis dans différents États membres de l’Union européenne se voient réclamer en justice des renseignements et des dommages et intérêts au sujet d’une infraction unique et continue à laquelle ils ont participé dans plusieurs États membres à des endroits et des époques différents (cette infraction à l’article 81 CE/101 TFUE et à l’article 53 de l’accord EEE ayant été constatée par la Commission européenne), le fait dommageable s’est produit, à l’égard de chaque défendeur et pour l’ensemble des dommages invoqués ou le dommage total, dans les États membres dans lesquels les ententes ont été conclues et mises en œuvre? »

Les conclusions de l’avocat général (Concl. De M. Niilo Jääskinen, 11 décembre 2014, CDC Cartel Damage Claims Hydrogen Peroxide SA contreEvonik Degussa GmbH et ae, C 352/13) invitent la Cour à adopter la position suivante : « par analogie avec ce que la Cour a dit pour droit dans l’arrêt Besix (EU:C:2002:99, point 55), je considère que la règle de compétence spéciale en matière délictuelle ou quasi délictuelle, qui est énoncée à l’article 5, point 3, du règlement Bruxelles I, est inopérante dans l’hypothèse où, comme dans le litige au principal, le lieu où le fait dommageable s’est prétendument produit ne peut pas être déterminé, en raison du fait que l’infraction à l’article 101 TFUE sur laquelle l’action est fondée consiste en des agissements qui se caractérisent par la multiplicité des endroits où ils ont été convenus et/ou exécutés, ce qui ne permet donc pas d’identifier clairement et utilement quelle serait la juridiction qui présenterait un lien particulièrement étroit avec l’ensemble du litige. »

La réponse à la question de la compétence internationale en matière de responsabilité délictuelle apparaît bien de plus en plus comme les délits évoqués dans cet article, complexe.

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