Court of Cassation: the agent may not claim the payment of commissions in case he has lost the commercial area (Il Sole 24 Ore, April 30, 2014, page 41)

Court of Cassation, with judgment no. 9226/2014, specified that once the agent disregarded the exclusivity of the area assigned he/she is not entitled to claim the payment of commissions regarding bargains concluded by the company – directly or through other agents – in such area. The Court stated that the exclusivity of the area assigned can be disregarded by the parties expressly or by facts. The “by facts” revocation, according to the Court, must be inferred in a “clear and univocal” way form the parties’ behavior if it is not in line with the content of the contract.