Key legal question
Whether the federal appeal was filed within the statutory time limit
Extracted holding
No; the appeal deadline expired on 2011-12-07 and the filing was made later.
Extracted reasoning
The challenged judgment was notified on 2011-11-07; under Art. 100 para. 1 LTF the 30-day deadline expired on 2011-12-07, while the appeal was only posted in Madagascar on 2011-12-15 and reached Swiss Post on 2012-01-22.