INTERNATIONAL JOURNAL OF TOURISM, TRAVEL AND HOSPITALITY LAW provisions of the Travel Directive . Notwithstanding this, Article 6.750(4)(3) of the Civil Code of the Republic of Lithuania established the definition of force majeure rather than extraordinary circumstances. The legal doctrine takes an analogous position with regard to the above definitions and their content (Fuehrich/Staudinger. Reiserecht, 2019, 8. Auflage, Verlag C.H.Beck, p.462; Bergmann/Blankenburg, NJW 2019, 3678). The national court in the present case also raised the question whether the definition of extraordinary circumstances is substantially different from the concept of force majeure. It has already been mentioned that the legal doctrine takes the position that the definition of force majeure has been changed to extraordinary circumstances only in order to unify the terms used in international conventions and in European Union legislation on passenger rights. Recital of point 31 of the Travel Directive identifies as exceptional circumstances, for example, war, other serious security problems such as terrorism, serious risks to human health such as the outbreak of a serious disease at the place of destination, or natural disasters such as floods or earthquakes, or meteorological conditions which make it impossible to travel safely to the place of destination. As can be seen from the examples given in the Travel Directive, these are traditional circumstances of unstoppable force (force majeure), as defined in Article 6.212 of the Civil Code of the Republic of Lithuania. The definition of unavoidable and extraordinary circumstances, according to the case-law of the Court of Justice(CJEU judgment in Case C-549/07, judgment in Case C-402/07 and C-432/07, judgment in Case C-501/17, etc.), is broader than that of force majeure, encompassing not only the external events referred to above, but also the internal events that are most often encountered by companies in the course of their business (e.g., strike etc.) (Bergmann/Blankenburg, NJW 2019, 3678; Loew, NJW 2020, 1252-1253; Tonner, MuenchKomm/BGB (8.Aufl.), 2020, Paragr. 651h, 34). Thus, it is reasonable to conclude that the concepts of force majeure ( Article 6.212 of the Civil Code of the Republic of Lithuania) and unavoidable and extraordinary circumstances (Article 6.750(4)(3) of the Civil Code of the Republic of Lithuania) used in Lithuanian national law can be equated when they include, among others, the classic external events of force majeure, which are also referred to in paragraph 31 of the recital of the Travel Directive . It should also be noted that Advocate General Laila Medina, in her opinion of 21 September 2023 in the case c-299/22, in response to a question posed by the Supreme Court of Lithuania on the relationship
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