In its “Rescue Drops” decision of September 19, 2016 (I ZB 34/15), the German Federal Supreme Court confirms the holding of the Higher Regional Court Munich that a cease and desist order, may contain the obligation to recall products even if this is not expressly stipulated in the judgment. The defendant had offered and advertised alcohol containing products under the name “RESCUE DROPS” and “RESCUE NIGHT SPRAY” and had delivered same to pharmacies. The Higher Regional Court Munich had considered this to be a health-related advertisement in context with alcohol and had enjoined it for constituting an act of unfair competition. The German Federal Supreme Court confirms that the defendant has to pay the fine because he did not attempt to recall the products which had been delivered to the pharmacies already prior to the enforcement of the judgment. The German Federal Supreme Court states: “The cease and desist obligation created by actions which still lead to a regular disruption of the market is to be interpreted to mean that not only these actions have to be stopped, but furthermore, possible and reasonable efforts are necessary to stop the continuous disruption of the market”.