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Re:81k UK-owned .eu domains suspended as Brexit transition ends by amscanne on Tuesday January 05, 2021 @12:38PM (#25648218)
Yes, this seems to be the most spiteful possible interpretation (especially before the new rules).

It seems easier and more sensible just to enforce the rules at renewal.

Re:81k UK-owned .eu domains suspended as Brexit transition ends by skington on Tuesday January 05, 2021 @01:21PM (#25648865)
That's unfair to people whose domains were up for renewal in January and February compared to November and December, though.