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Law. 56 Therefore, it hardly comes as a surprise that the PLR 
is based on an international treaty. What makes the PLR 
special is the fact that, while the Athens Convention had 
already entered into force, at the time the European 
authorities took action by adopting the PLR, it had not yet 
entered into force in the version that was ultimately 
implemented by the EU in 2012. At the time the PLR was 
created, Europe had already gone beyond its obligations 
under the Athens Convention and implemented the PAL 
2002. Indeed, the PAL 2002 was not yet binding at the time 
PLR became applicable, let alone when PLR was created. 
The international origin of the PLR is unusual from 
the perspective of consumer law, but it can be easily 
explained given the transboundary nature of modern 
travel. 57 In the member states of the European Union, 
regardless of the mode of transportation, passenger laws 
have become three-layered: consisting of domestic law, 
European law, and international law. 58 This can lead to a 
number of conflicts between different legal regimes, 
particularly because some EU member states have ratified 
the original 1974 Athens Convention 59 and the PLR went 
beyond the 1974 Convention and the PAL 2002. 
56 Jens Karsten, Passagierrechte und Passagierbegriff im Gemeinschaftsrecht 
und die Überarbeitung des Gemeinschaftlichen Besitzstandes im 
Verbraucherrecht, 6 Verbraucher und Recht 201, 202 (2008). 
57 Id. at 204. 
58 Id. at 205. 
59 For the current status of ratifications of Conventions in international 
shipping law, see Status of multilateral Conventions and instruments in 
respect of which the International Maritime Organization or its Secretary- 
General performs depositary or other functions, International Maritime 
Organization, 
http://www.imo.org/ en/ About/Conventions/StatusOfConventions/D 
ocu m en Is/Sla Lu s % 20-% 202015. pd f (last visited Nov. 5, 2015) (this