> Now, the Supreme Court of the Netherlands must determine whether the geo-blocking used by the website was state of the art and effective in practice. If so, the intended audience would not have included Dutch users, and no communication would have been made to the public in the Netherlands.

This seems extremely problematic, depending on what "state of the art and effective" means. It seems like blocking VPN users is unfortunately still on the table, as are other invasive enforcement methods.