At the beginning, the decision (revolutionary at that time) of the French Court of Appeal (1879) was observed. In the decision, the court found out that a company is entitled to participate as a shareholder of another company.
Another conceptual shift was marked by the decision of Rozenblum case (1985) in which the court concluded that the interest of a group of companies can temporarily prevail against sole interest of one of its members. Furthermore, the contribution dealt with the current issue of which rights can be attached to shares and whether and under what conditions a share in profit of the group member can be attached to shares of the controlling or controlled company, collectively, whether so-called groups shares, regulated by French law, could be created.