Can you say class action in German? Nein.

Andreas Tilp was born in Plochingen, Germany, studied law a short train ride away in Tübingen, and works in the neighboring town of Kirchentellinsfurt. In what could be the biggest case of his decades of practice, he’s representing hundreds of clients in a lawsuit against that most German of companies, Volkswagen, which will be heard in a courtroom in Braunschweig, a 45-minute drive from VW’s headquarters. Sometimes, Tilp wishes he were American. “The German system is totally hostile to plaintiffs,” he says in the converted 1920s textile mill that serves as his office. “It’s no surprise that investors sue in the U.S. whenever they can.”

Tilp represents shareholders seeking damages of €5.2 billion ($5.4 billion) from Volkswagen. They say the company was late in disclosing a U.S. probe into cheating on emissions tests, an allegation VW denies. If the case were brought in the U.S., it would likely be easier to reach a settlement, as American attorneys did when they sued VW on behalf of car owners. Eight months after the emissions scandal broke, VW agreed to a $10 billion deal that provided U.S. buyers with as much as $10,000 each—and the plaintiffs’ attorneys with $175 million.