It has only been a little over four years since the European Court of Justice fundamentally decided that legal entities also benefit from the privilege of freedom of establishment. Although this decision was not surprising for European law experts, it did trigger an earthquake. The English Limited, which can be established quickly and cheaply without significant bureaucratic burden or minimum capital, set out to conquer the continent despite all the naysayers. As of mid-2007, there are an estimated 45,000 German Limiteds, of which only a fraction—about 10,000 according to another estimate—are registered in German commercial registers. This also highlights the issue: Limiteds are easy to establish, but difficult to manage in Germany. No wonder, considering the circumstances.