What to consider a restriction of competition under Article 101 (1) is complex. However, the text of Article 101 (1) refers to agreements that are anti-competitive by object or by effect. A segregation utilized in early cases such as Consten and Grundig and Société Technique Minière. Both from 1966 and both involving the appraisal under Article 101 (1) of exclusive distribution agreements. In the first, the parties had attempted to (ab)use an exclusive distribution agreement to prevent parallel imports from outside the allotted territory, which was detrimental to the object of Article 101 (1). In the latter, the Court of Justice stated that restriction by object or effect was not cumulative, but two alternative ways of analyzing potential restrictions.