COCOO CASES

Jun

2025

www.consult.lobbyist.reg.uk

Full URL: https://www.gov.uk/government/publications/register-of-consultant-lobbyists

Strategic Imperative

The Register of Consultant Lobbyists provides a list of third-party lobbying firms and, crucially, the clients they have lobbied for in each quarter. Its strategic value is in identifying the outsourced influencing efforts of our adversaries. When a company wants to influence policy without using its own name directly in meetings, it often hires a specialist consultancy. This register tells us who is hiring whom.

This platform is mission-critical for:

Competitor Analysis: Discovering that a competitor has hired a high-powered lobbying firm is a “Simple Indicator” that they are preparing a major push to influence government policy in their favour. ¹¹¹¹¹¹¹¹¹
Informing our “Lobby Tools” Strategy: This register is a primary “Lobby Tool”. ² It allows us to map the professional lobbying network, identifying which firms work for our adversaries and which might be available to us.
Executing the “PTW (Political Time Window)” Doctrine: Identifying a flurry of new lobbying activity by a competitor can signal that a key government decision or consultation is imminent, allowing us to time our own intervention for maximum impact within that “Political Time Window”. ³³³³
Supporting “Challenge Discrpower”: While not direct proof of impropriety, demonstrating that a company which benefited from a discretionary government decision had recently paid lobbyists to meet with that same department adds important context to a legal challenge. ⁴

Part I: The Search Platform’s Rules & Functionality

This platform is not a dynamic search database. It is an archive of official publications. Its use requires downloading and manually analyzing spreadsheet files.

Publication Format: The Register is published quarterly as a downloadable spreadsheet file (CSV or ODS format). There is no online search form. All analysis is conducted offline within the downloaded file.
Data Structure: The spreadsheet contains several key columns:
- Name of consultant lobbyist: The name of the lobbying firm.
- Name(s) of client(s): The name of the company that paid for the lobbying. This is the most important data field for us.
- Period covered by return: The specific quarter the lobbying took place.
Search Method: The only way to “search” the register is to:
1. Download the spreadsheet for each quarter of interest.
2. Open the file in a spreadsheet program (e.g., Microsoft Excel).
3. Use the program’s “Filter” or “Find” (Ctrl+F) functions to search for keywords within the Name(s) of client(s) column.

Part II: The COCOO Strategic Forensic Protocol

This protocol provides a systematic workflow for extracting intelligence from the quarterly register files.

Phase 1: Proactive & Reactive Monitoring

Step 1.1: New Register Download: The moment a new quarterly register is published, it must be downloaded and archived in our system.
Step 1.2: Adversary Watchlist Search: Immediately upon download, run a “Find” (Ctrl+F) search within the new spreadsheet for every company and parent company on our UK adversary watchlist. Any match is a significant intelligence finding.
Step 1.3: Historical Baseline Analysis: To understand a target’s history, you must download the registers for the last 8-12 quarters and search for the target’s name across all files to identify their historical lobbying footprint.

Phase 2: The Influence Network Mapping Protocol

Step 2.1: Identify the Client: When a search identifies a competitor in the Name(s) of client(s) column, this is the primary finding.
Step 2.2: Identify the Lobbying Firm: Note the name of the lobbying firm they have hired from the Name of consultant lobbyist column.
Step 2.3: Reverse-Engineer the Lobbyist’s Network: Conduct a new search within the same spreadsheet for the lobbying firm’s name. This will generate a list of all their other clients for that quarter. This is crucial for two reasons:
- It reveals potential undeclared coalitions (if multiple competitors are all hiring the same lobbyist).
- It helps us understand the lobbying firm’s specialisms and political connections.

Phase 3: Intelligence Synthesis & Strategic Action

Step 3.1: Correlate with Policy Events: Cross-reference the dates of the lobbying activity with the government’s policy calendar. Did our competitor hire a lobbyist in the quarter immediately preceding a major consultation on competition rules in their sector? This suggests they were attempting to influence the outcome.
Step 3.2: Inform Counter-Lobbying: Knowing which lobbying firm an adversary uses is a tactical advantage. We can anticipate the arguments they are likely to make (based on the firm’s other clients and past work) and prepare our own counter-arguments for direct submission to the relevant government department.

Part III: Application to COCOO Doctrines

This model is designed to provide tactical intelligence that feeds our broader strategic plays.

Mind Map Doctrine	Application of the Consultant Lobbyists Register Model
Lobby Tools	This register is a direct “Lobby Tool”, revealing the outsourced lobbying machinery of our adversaries and informing our own public affairs strategy. ⁵
PTW (Political Time Window)	A sudden appearance of a competitor on this register is a strong signal that a “Political Time Window” is opening, prompting us to prepare our own intervention. ⁶⁶⁶⁶
Benchmarking / Competitor Analysis	Discovering that a competitor is investing in third-party lobbying provides a key data point for our “Competitor Analysis”, indicating their level of seriousness about influencing policy. ⁷⁷⁷⁷
Noisefilter	A competitor’s public statements on a policy issue are noise. The fact they are paying a lobbying firm, as recorded in this register, is a verifiable signal of their true intent and commitment. ⁸⁸⁸⁸
Challenge Discrpower	This intelligence adds context to a challenge. We can state that a government decision which benefits a specific company was made following a period where that same company was paying lobbyists to influence the decision-making department. ⁹

Jun

2025

SEC.EDGAR.USA (sh id)

SEARCHLINKS

Full URL: https://www.sec.gov/edgar/search-and-access

Strategic Imperative

The EDGAR system is the primary source for all mandatory filings by public companies in the U.S. Its strategic value is immense, as it provides a detailed, regulated view into corporate strategy, financial health, and ownership. The intelligence gathered from EDGAR is essential for executing our core doctrines in the world’s largest economy.

This platform is mission-critical for:

MATOIPO (Merger, Acquisition, Takeover…) Analysis: EDGAR is the definitive source for official M&A filings, including merger agreements (Form 8-K) and prospectuses (Form S-4). ¹
Detecting “Stealth Consolidation”: Scrutinizing Schedule 13D and 13G filings is the primary method for tracking activist investors and hostile parties building stakes in target companies, a key element of “Stealth Consolid”. ²²²²²²
Uncovering Undisclosed Mergers: The detailed financial statements within annual (10-K) and quarterly (10-Q) reports are essential for our methodology of identifying undisclosed merger activity. ³³³³³³ The Barrios & Wollmann paper confirms that analyzing these financial reports is the key to measuring the trillions in undisclosed deals. ⁴⁴⁴⁴
Finding Evidence for Litigation: The “Management’s Discussion and Analysis” (MD&A) section of a 10-K report often contains admissions of market risks, competitive threats, and ongoing litigation that can be used as evidence. ⁵⁵

Part I: The Search Platform’s Rules & Functionality

EDGAR offers several search interfaces. Using the correct tool for the task is crucial. The main access page links to different search functions.

“Full-Text Search for Filings”: This is a powerful keyword search tool.
- Supports Boolean operators (AND, OR, NOT).
- Supports proximity searches (e.g., merger NEAR/15 agreement).
- Allows filtering by specific Filing type (e.g., 8-K, 10-K, 13D), Company name, and Date range.
“Search by Company or Fund Name”: This takes you to a company’s specific filing history page.
- Once on a company’s page, you can filter the results by Filing type.
Key SEC Form Types for COCOO:
- 10-K: Annual Report. Provides a comprehensive overview of the business, risk factors, financial data, and MD&A. ⁶⁶⁶⁶
- 10-Q: Quarterly Report. An update on the 10-K. ⁷⁷⁷⁷
- 8-K: Current Report. Used to announce major events, including merger agreements, asset acquisitions, and changes in directors. This is the U.S. equivalent of a material event RNS. ⁸⁸⁸⁸
- Schedule 13D: Filed by an entity that acquires more than 5% of a company’s stock with intent to influence the company. This is a critical filing for tracking activist and hostile activity.
- Schedule 13G: Filed by an entity that acquires more than 5% of a company’s stock but has no intent to influence (i.e., a passive investment). Comparing a 13G filing to a later 13D filing by the same party is a clear signal of escalating intent.
- Form S-4: Registration statement for securities issued in a business combination (merger). Often contains the full merger agreement as an exhibit. ⁹

Part II: The COCOO Strategic Search Model for EDGAR

This protocol provides a workflow for any investigation involving a U.S.-listed company.

Phase 1: The “Stealth Consolidation” & Activist Watch

This protocol is for proactively identifying stake-building.

Step 1.1: Thematic Search: Use the “Full-Text Search” tool. Set a date range for the last 30 days and filter the Filing type to 13D. In the search box, use keywords for our target sectors (e.g., "biotechnology" or "logistics"). This will generate a list of all recent activist campaigns in those sectors.
Step 1.2: Target Company Analysis: Once an interesting 13D filing is identified, pivot to the “Search by Company or Fund Name” tool. Pull up the target company’s page.
Step 1.3: Review Recent History: On the target’s page, review all 8-K filings from the past 6 months. Look for any director changes or strategic announcements that may have preceded the activist’s filing. Also, check for any prior 13G filings by the same activist to see when they first crossed the 5% threshold passively.

Phase 2: The M&A and Financial Health Protocol

This is the standard protocol when analyzing a specific company.

Step 2.1: Retrieve Foundational Documents: On the company’s EDGAR page, download the most recent 10-K and all subsequent 10-Q reports.
Step 2.2: Forensic Financial Review: Scrutinize the financial statements, particularly the cash flow statement. Compare the acquisitions line item with publicly announced deals to search for evidence of undisclosed mergers, as per the Barrios & Wollmann methodology. ¹⁰¹⁰¹⁰¹⁰
Step 2.3: Analyze Management’s Discussion (MD&A): Text-search the MD&A section of the 10-K for keywords like "risk", "competition", "litigation", and "regulation". Management’s own description of their vulnerabilities is a primary source of evidence. ¹¹¹¹
Step 2.4: Extract Merger Agreements: If a merger is announced via an 8-K, locate that filing. The full merger agreement is often attached as Exhibit 2.1. This document contains the specific terms, conditions, and representations that can be challenged.

Part III: Application to COCOO Doctrines

This model directly executes our strategies within the U.S. regulatory framework.

Mind Map Doctrine	Application of the EDGAR Portal Model
Stealth Consolid	The “Stealth Consolidation & Activist Watch” protocol (Phase 1) is our primary method for detecting this in the U.S. market by systematically tracking Schedule 13D filings. ¹²¹²¹²¹²
MATOIPO Analysis	The M&A Protocol (Phase 2), specifically the retrieval of 8-K and S-4 filings, provides the core documents needed to analyze and challenge any public merger or acquisition in the U.S. ¹³¹³¹³¹³
Undisclosed Mergers / Stealth Consolidation	The Forensic Financial Review (Step 2.2) is a direct application of the academic methodology to find evidence of undisclosed mergers that contribute to stealth consolidation. ¹⁴¹⁴¹⁴¹⁴¹⁴¹⁴¹⁴¹⁴¹⁴
Noisefilter	A company’s press release is noise. ¹⁵ Its 10-K filing, written under penalty of law, is the verifiable signal. ¹⁶¹⁶¹⁶¹⁶ EDGAR allows us to filter out the marketing and focus on the legally binding disclosures.
Simple Indicators	An 8-K filing announcing the unexpected resignation of a Chief Financial Officer, or a new risk factor disclosed in a 10-Q, are “Simple Indicators” of potential corporate distress that warrant deeper investigation. ¹⁷
Challenge Discrpower	If the SEC reduces disclosure rules, we can use the 10-K filings of companies to find evidence of how those weaker rules are allowing anticompetitive mergers to remain hidden, forming the basis of a submission arguing for the rule to be strengthened. ¹⁸

Jun

2025

www.lse.shareholder.identification

SEARCHLINKS

Full URL: https://www.londonstockexchange.com/news?tab=news-explorer

The LSE News Explorer is the definitive, official source for all price-sensitive announcements made by UK-listed companies¹. Its strategic value lies in its timeliness and comprehensiveness. It is where mergers are announced, where stake-building is revealed, and where directors’ dealings are disclosed. This platform is the engine room of our “RNS OC OS” strategy², where a Regulatory News Service (RNS) announcement acts as the trigger for deeper investigation using OpenCorporates (OC) and OpenSanctions (OS).

This platform is mission-critical for:

MATOIPO (Merger, Acquisition, Takeover…) Analysis: It is the primary source for all official M&A announcements for UK-listed companies³³³.
Detecting “Stealth Consolidation”: The “Holding(s) in Company” announcements are the key to identifying the incremental stake-building that precedes a formal takeover⁴⁴⁴⁴⁴⁴⁴⁴.
“TOP FCA Review” Equivalent: By monitoring director dealings and holdings disclosures, we can scrutinize pre-bid activity and identify potential market manipulation or breaches of disclosure rules⁵.
Finding “Simple Indicators”: Announcements such as “Result of AGM,” “Directorate Change,” or “Strategic Review” can be “Simple Indicators” ⁶⁶ of corporate instability or a change in strategy that presents an opportunity for COCOO.

Part I: The Search Platform’s Rules & Functionality

The News Explorer is a powerful filter-based search tool. Mastering its specific filters is key to precision targeting and eliminating noise.

Keyword Search (Search news): A full-text search across the headline and body of the RNS announcements. Supports exact phrase searching using double quotation marks (" ").
Key Filters (on the left-hand panel):
- Headline: This is the most powerful filter. It allows you to select specific, structured announcement types. For our purposes, the most critical are⁷⁷⁷:
  - Holding(s) in Company
  - Mergers, Acquisitions and Disposals
  - Director/PDMR Shareholding
  - Takeovers and Mergers
- Sector: Filters by industry sector (e.g., Financial Services, Technology).
- Company: Filters for all announcements from a specific company.
- Date Range: Allows searching within a specific period, essential for historical analysis and correlating events.

Part II: The COCOO Strategic Search Model for the LSE News Explorer

This protocol provides a systematic workflow for any investigation involving a UK-listed company.

Phase 1: Proactive Sectoral & Adversary Monitoring

Step 1.1: Daily “MATOIPO” Sweep: First action each day is to filter by the Headline types Mergers, Acquisitions and Disposals and Takeovers and Mergers with a date range of the last 24 hours. This provides a complete list of all official M&A activity.
Step 1.2: Weekly “Stealth Consolid” Sweep: Run a weekly search filtering by the Headline type Holding(s) in Company for our target sectors. This identifies all changes in significant shareholdings, which is our primary early warning system for stake-building.
Step 1.3: Adversary Watchlist: Maintain a list of our key UK-based adversaries and competitors. Run a weekly search filtering by their Company name to capture all their announcements, regardless of type.

Phase 2: The “Trigger Event” Analysis Protocol

This protocol is activated when a significant announcement is identified.

Step 2.1: Initial RNS Analysis: When a “Holding(s) in Company” announcement is flagged, identify the acquiring entity and the percentage stake they have acquired. When a “Mergers, Acquisitions and Disposals” announcement is flagged, identify the target and the terms of the deal.
Step 2.2: Launch the “RNS OC OS” Protocol:
- OC (OpenCorporates): Immediately run the names of the acquirer and target through OpenCorporates to map their corporate structures and identify directors⁸⁸⁸⁸.
- OS (OpenSanctions): Run the names of the acquirer, target, and their key directors/BOs through OpenSanctions to check for sanctions or PEP (Politically Exposed Person) status⁹⁹⁹⁹.
Step 2.3: Historical Context Search: Conduct a new search on the News Explorer for the target company, looking at all announcements over the last 12-24 months. Look for patterns: Has there been a prior “Strategic Review”? A “Profit Warning”? A series of “Director/PDMR Shareholding” sales? This context is crucial for understanding the motivation behind the transaction.

Phase 3: Intelligence Synthesis & Strategic Action

Step 3.1: Identify the Anomaly: Synthesize the data. Does the RNS announcement reveal an acquirer whose ultimate beneficial owner (found via OC) is a sanctioned individual (found via OS)? This is a major red flag that can be used to challenge the deal on public interest grounds.
Step 3.2: Build the “Stealth Consolidation” Case: Aggregate multiple Holding(s) in Company RNS filings over time. By showing that a single entity has moved from a 3% stake to 5%, then to 10%, then to 20%, we can build a clear narrative of a “creeping takeover” and present this to regulators as evidence of a “significant lessening of competition” that warrants investigation¹⁰¹⁰¹⁰¹⁰.

Part III: Application to COCOO Doctrines

This model is the engine that drives our UK-based proactive case origination.

Mind Map Doctrine	Application of the LSE News Explorer Model
MATOIPO	The `Mergers, Acquisitions and Disposals` filter is our direct, real-time feed for all MATOIPO events in the UK public markets¹¹¹¹¹¹.
Stealth Consolid	The `Holding(s) in Company` filter is the primary tool for detecting the incremental stake-building that defines a “Stealth Consolid” strategy¹²¹²¹²¹²¹²¹²¹²¹²¹².
RNS OC OS	The entire protocol is a direct implementation of this core COCOO strategy, using the RNS as the trigger for deeper intelligence work¹³¹³¹³.
Noisefilter	The LSE News Explorer is the “Noisefilter”¹⁴¹⁴¹⁴¹⁴. It filters out market rumour and speculation, providing only the official, regulated announcements that serve as verifiable evidence.
Simple Indicators	Announcements like “Directorate Change” or “Final Results” are not just routine; they can be “Simple Indicators” ¹⁵¹⁵¹⁵¹⁵ of underlying health or distress, which this platform allows us to monitor systematically.
TOP FCA review	Monitoring `Director/PDMR Shareholding` announcements around major M&A news allows us to scrutinize for potential insider dealing or improper disclosure, forming the basis for a complaint to the FCA¹⁶.

Jun

2025

www.usa.oge.gov

SEARCHLINKS

Full URL: https://www.oge.gov/web/oge.nsf/Disclosures

Strategic Imperative

The OGE portal provides access to the declared financial interests of officials across the U.S. executive branch, including powerful regulatory bodies such as the Securities and Exchange Commission (SEC) and the Federal Trade Commission (FTC). This intelligence is fundamental to executing our core doctrines in the American market. It enables us to challenge the impartiality of regulatory decisions and identify hidden leverage points. ¹¹¹¹

This platform is mission-critical for:

Challenging U.S. Regulatory Decisions: This is the primary tool for our “Challenge Discrpower” doctrine in the U.S. ²²²² If the FTC or DOJ clears a merger we believe is anticompetitive, or the SEC reduces disclosure requirements, we must investigate the financial interests of the officials who made that decision. ³³³ Evidence of a conflict can be used to challenge the decision’s legitimacy.
Informing “MATOIPO Analysis”: For any merger involving U.S.-listed companies, especially those requiring regulatory approval from agencies like the FTC, analyzing the disclosures of the relevant agency heads is a critical due diligence step. ⁴⁴⁴⁴⁴⁴⁴
Uncovering Rationale for “Stealth Consolidation”: The OGE portal can help us understand the regulatory environment that permits “stealth consolidation” to occur. ⁵⁵⁵⁵⁵⁵⁵⁵⁵ Are the regulators responsible for policing these mergers financially invested in sectors known for such activity?
Identifying U.S. “Enforcement Gaps”: When we identify an “Enforcement Gap”, we must investigate the financial declarations of the leadership at the responsible agency to determine if personal financial interests are a contributing factor to their inaction. ⁶

Part I: The Search Platform’s Rules & Functionality

The OGE portal is a structured search tool for locating specific disclosure reports, which are then presented as PDF documents. It is not a full-text search engine for the contents of those documents.

Primary Search Fields:
- Search By Filer Name: The main search box. You can enter the last name, or “last name, first name” for more precision.
- Filter By Agency: A dropdown menu to select a specific government agency (e.g., Federal Trade Commission, Department of Justice, Securities and Exchange Commission). This is a critical filter for our work.
- Filter By Document Type: Allows you to select the type of filing. The most important for our purposes is the “New Entrant” or “Annual” Public Financial Disclosure Report (OGE Form 278e).
- Filter By Year: Allows selection of the calendar year the report was filed.
Search Logic:
- The system searches for public records filed by presidentially appointed, Senate-confirmed (PAS) officials.
- The search results provide a link to the official, certified PDF of the disclosure report. The actual investigation takes place within this document.

Part II: The COCOO Strategic Forensic Protocol

This protocol provides a systematic workflow for any case involving a U.S. federal agency.

Phase 1: Target Identification

Step 1.1: Identify the Key U.S. Official: In any case involving a U.S. federal agency (e.g., an FTC merger review, an SEC rule change), identify the senior officials responsible. This includes the agency Chair, Commissioners, or other key political appointees.
Step 1.2: Define the Time Period: Note the relevant time period for the decision or action being investigated.

Phase 2: The Search and Document Retrieval Protocol

Step 2.1: Agency-Specific Search: On the OGE portal, use the Filter By Agency dropdown to select the agency of interest (e.g., “Federal Trade Commission”).
Step 2.2: Locate the Target Official: Enter the official’s last name in the Search By Filer Name box. Filter by the relevant Year to narrow the results.
Step 2.3: Download All Relevant Reports: Download the “Annual” disclosure reports for the years leading up to and including the decision under investigation. Also, download the “New Entrant” report to see the official’s financial status upon entering government service.

Phase 3: Forensic Document Review

This is the most critical phase, requiring manual review of the downloaded PDF reports.

Step 3.1: Systematic Keyword Search: Open the PDF report and use the “Find” function (Ctrl+F or Cmd+F) to search for keywords relevant to your case. This includes:
- The names of the companies involved in the merger or investigation.
- The names of major investment funds (e.g., Blackstone, Carlyle) that may be backing the companies.
- The names of the industry’s primary law firms or lobbying groups.
- Ticker symbols of relevant public companies.
Step 3.2: Analyze Financial Holdings: Scrutinize the “Part 6: Other Assets and Income” section of the report. Look for shareholdings, mutual funds, or other financial instruments that could be affected by the agency’s decisions. Note that even holdings in broad index funds can be relevant if a particular merger would significantly impact that index.
Step 3.3: Compare Year-over-Year: Compare the official’s annual reports over several years. Look for significant changes in assets, particularly the acquisition of stocks or funds in an industry shortly before a major regulatory decision affecting that industry.

Part III: Application to COCOO Doctrines

This model is designed to provide the high-level evidence needed to challenge the integrity of U.S. regulatory actions.

Mind Map Doctrine	Application of the OGE Portal Model
Challenge Discrpower ⁷⁷	This is the primary application. Documented evidence of a potential conflict of interest from an OGE report is the strongest basis upon which to challenge a discretionary decision by a U.S. regulator, arguing it was arbitrary, capricious, or biased.
MATOIPO Analysis ⁸	For any U.S. merger requiring HSR clearance, this protocol must be run on the FTC and DOJ leadership to assess the risk of a biased review. ⁹⁹⁹⁹ This intelligence informs our strategy for engaging with the agencies.
PTW (Political Time Window) ¹⁰	A conflict of interest involving a high-level U.S. official has maximum impact if revealed during a sensitive time, such as their Senate confirmation hearing for a new post or during a congressional oversight hearing of their agency.
Noisefilter ¹¹¹¹¹¹¹¹	An agency’s public justification for a decision is “noise.” An official’s OGE disclosure showing a financial interest in the outcome is the “signal” that may reveal the true motivation.
Enforcement Gap ¹²	If we identify a pattern of under-enforcement in a sector (e.g., allowing “stealth consolidation” ¹³¹³¹³¹³¹³¹³¹³¹³¹³), we will use the OGE portal to investigate whether the leadership of the responsible agency has conflicting financial ties to that same sector.

Jun

2025

ec.commissioners.discl

SEARCHLINKS

Full URL: https://ec.europa.eu/commission/commissioners/2019-2024_en

Strategic Imperative

The Declarations of Interests of the College of Commissioners is the definitive source for the private financial interests of the EU’s executive branch. This intelligence is fundamental to our EU-level strategies, particularly those involving challenges to the European Commission itself.

This platform is mission-critical for:

Challenging EC Decisions: This is a primary tool for our “Challenge Discrpower” doctrine at the highest level¹¹¹¹. If the Commissioner for Competition approves a controversial merger or state aid package, evidence of their financial interest in one of the parties can be used to challenge the legality and impartiality of that decision before the General Court (GC) or the European Court of Justice (ECJ)²²²².
Informing “State Aid” and “EC/CMA” Complaints: Before submitting a complaint to the EC about illegal state aid or anticompetitive behaviour, we must analyze the declarations of the relevant Commissioners³³³³. This allows us to assess potential biases and tailor our arguments accordingly.
Executing the “PTW (Political Time Window)” Doctrine: A conflict of interest involving a Commissioner is a matter of significant public and political interest across the EU⁴. Revealing such a conflict during a sensitive period—such as the run-up to European Parliament elections or during a hearing for a new Commissioner—provides maximum leverage.

Part I: The Search Platform’s Rules & Functionality

This platform is an official public archive, not a searchable database. Its use requires targeted, manual investigation.

Publication Format: The portal is a landing page that lists all Commissioners for the 2019-2024 term. There is no central search bar to query across all declarations.
Access Method: To access the information, you must click on the portrait or name of the specific Commissioner you wish to investigate. This leads to their individual profile page.
Location of Declarations: On the individual Commissioner’s page, their “Declaration of Interests” is available as a PDF document. This document is the target of our investigation.
Content of Declarations: The declaration is a standardized form that includes sections for:
- Financial interests: Shareholdings, bonds, and other financial instruments.
- Assets: Real estate and other significant assets.
- Spouse’s professional activity: The professional role of the Commissioner’s spouse.
- Membership of boards: Positions held on boards of foundations, NGOs, or other bodies.

Part II: The COCOO Strategic Forensic Protocol

This protocol provides a systematic workflow for any investigation involving a European Commission decision.

Phase 1: Target Identification

Step 1.1: Identify the Relevant Commissioner: For any given case, identify the Commissioner whose portfolio covers the issue. For our purposes, this will most often be the Commissioner for Competition, the Commissioner for the Internal Market, or the Commissioner responsible for a specific industry (e.g., Energy, Health).
Step 1.2: Identify their “Cabinet”: On the Commissioner’s profile page, review the members of their “Cabinet” (their team of advisors). The names of these senior advisors are also valuable intelligence for mapping influence networks.

Phase 2: Forensic Document Review

Step 2.1: Download the Declaration: Navigate to the target Commissioner’s profile and download their “Declaration of Interests” PDF.
Step 2.2: Systematic Keyword Search: This is the crucial step. Open the PDF and conduct a thorough “Find” (Ctrl+F or Cmd+F) search for keywords relevant to your case. This must include:
- The names of all companies involved (e.g., the parties to a merger, the recipient of state aid).
- The names of major investment funds or asset managers known to be active in the sector⁵.
- The names of parent companies and significant subsidiaries⁶.
- Keywords for the industry itself (e.g., automotive, pharmaceutical).
Step 2.3: Spousal Conflict Analysis: Pay close attention to the declared professional activity of the Commissioner’s spouse. This is a common and often overlooked source of potential conflicts of interest.

Phase 3: Intelligence Synthesis & Strategic Action

Step 3.1: Document the Conflict: If a link is found, create a dossier containing the excerpt from the declaration and evidence of the corresponding Commission decision that benefits that financial interest.
Step 3.2: Formulate the Legal Challenge: This documented conflict becomes a cornerstone of any legal challenge. In a submission to the General Court, we would argue that the decision is void due to a breach of the principle of impartiality, a fundamental tenet of EU administrative law. This directly supports our “JR. CAT, ECJ” strategy⁷⁷.
Step 3.3: Inform Public Affairs Strategy: The evidence can be shared (under strict legal guidance) with trusted journalists or Members of the European Parliament (MEPs) to raise public and political pressure on the Commission, making it harder for them to defend their decision.

Part III: Application to COCOO Doctrines

This model is designed to provide the high-level evidence needed to challenge the European Commission itself.

Mind Map Doctrine	Application of the Commissioners’ Declarations Model
Challenge Discrpower / JR2COURT	This is the primary application. Finding a conflict of interest in a Commissioner’s declaration is the most powerful evidence available to challenge their discretionary decisions and forms the basis of an appeal to the ECJ⁸⁸⁸⁸.
EC/CMA, SOSET, State Aid Cases	Before filing any major competition or state aid complaint with the EC, this protocol must be executed to understand the financial interests of the ultimate decision-maker, allowing us to anticipate potential biases⁹⁹⁹⁹.
PTW (Political Time Window)	The discovery of a significant conflict of interest involving a Commissioner is a major political event. Timing the disclosure of this information to coincide with key events in the EU calendar (e.g., State of the Union address, major legislative votes) will create a political firestorm and maximize our leverage¹⁰.
Noisefilter	The Commission’s public press releases explaining a decision are “noise.” The Commissioner’s private financial declaration is the “signal” that may reveal the true interests behind that decision¹¹¹¹¹¹¹¹.

Jun

2025

www.ukparl.interest.disclosures

SEARCHLINKS

Full URL: https://www.parliament.uk/mps-lords-and-offices/standards-and-financial-interests/parliamentary-commissioner-for-standards/registers-of-interests/register-of-members-financial-interests/

Strategic Imperative

The Register of Members’ Financial Interests is our key tool for investigating the specific financial activities and relationships of elected Members of Parliament (MPs). This is essential for understanding the potential for bias in legislative and regulatory processes. It is a cornerstone of our “Challenge Discretionary Power” doctrine, as it allows us to question the impartiality of decisions made by or influenced by MPs with relevant outside interests.

This platform is mission-critical for:

Uncovering Conflicts of Interest: Identifying MPs who hold shares in, or receive payment from, companies that are subject to regulatory decisions or are bidding for public contracts we are monitoring.
Executing the “PTW (Political Time Window)” Doctrine: The register provides the leverage to intervene at a moment of maximum political sensitivity, such as when an MP with a conflict is scheduled to speak in a debate or vote on a relevant bill.
Informing our “Lobby Tools” Strategy: Understanding an MP’s financial interests helps us identify potential allies (those with no conflicting interests) and adversaries (those with clear financial conflicts).
Supporting “FOC DAM” (Find Other Claimants): If an MP’s actions, influenced by a declared interest, have caused harm, it may open up avenues to find other parties who have been similarly disadvantaged.

Part I: The Search Platform’s Rules & Functionality

This platform is not a searchable database but a formal publication. Its use is a process of manual, forensic review.

Publication Format: The Register is published as a single, comprehensive document, typically in HTML and sometimes as a PDF. It is not a filterable database.
Structure: The Register is organised alphabetically by MP’s surname. Under each MP’s name is a list of their declared interests, categorised into specific sections.
Search Method: The only way to “search” the register is to use your browser’s built-in “Find” function (Ctrl+F or Cmd+F) to search for keywords (e.g., a company name, a director’s name) within the single document.
Key Categories of Declared Interests: Understanding the categories is crucial for analysis:
- Category 1: Employment and earnings: Includes salaries, fees, and payments from any employment outside of Parliament.
- Category 2: Donations and other support: Financial or in-kind support received by the MP or their local party.
- Category 3: Gifts, benefits and hospitality: Any gifts or benefits received from UK or foreign sources.
- Category 7: Shareholdings: This is a critical category, detailing shareholdings in companies that exceed 15% of the issued share capital or have a value over £70,000.
- Category 8: Land and property: Declarations of property owned that has significant value or provides an income.

Part II: The COCOO Strategic Forensic Protocol

This protocol provides a systematic workflow for extracting actionable intelligence from the Register.

Phase 1: Proactive & Reactive Target Identification

Step 1.1: Adversary-Linked Search: For any UK-based case, compile a list of all associated company names, director names, and parent companies. Systematically run a “Find” (Ctrl+F) search for each of these keywords within the full Register document.
Step 1.2: Thematic Search: Run “Find” (Ctrl+F) searches for keywords related to our target sectors (e.g., “pharmaceutical,” “energy,” “construction,” “litigation funding”). This will identify all MPs with declared financial interests in those specific industries.
Step 1.3: Committee Analysis: Identify the MPs who sit on parliamentary committees relevant to our case (e.g., the Business and Trade Committee, the Health and Social Care Committee). These individuals are our primary targets for a detailed review of their declared interests.

Phase 2: The Conflict of Interest Mapping Protocol

Step 2.1: Extract and Record: When a keyword search yields a match, carefully extract the full details of the declaration: the name of the MP, the category of interest, the name of the company/person providing the benefit, the value of the interest, and the dates.
Step 2.2: Cross-Reference with Parliamentary Activity: Take the name of the MP with a declared interest. Go to the main Parliament website (parliament.uk) and search for their recent activity. Look for:
- Questions they have asked in Parliament (Hansard records).
- Debates they have spoken in.
- Early Day Motions they have signed. The goal is to find a direct correlation between their private financial interests and their public parliamentary actions.
Step 2.3: Synthesize the Evidence: Create a simple dossier for the target MP, containing two key elements:
1. The official entry from the Register of Interests.
2. The record of their corresponding parliamentary activity (e.g., the transcript of a speech advocating for a policy that benefits a company in which they hold shares).

Phase 3: Strategic Leverage

Step 3.1: Formal Complaint: The documented link between an MP’s financial interests and their public actions can form the basis of a formal complaint to the Parliamentary Commissioner for Standards, alleging a breach of the code of conduct.
Step 3.2: Informing Legal Submissions: This evidence can be submitted in a judicial review or a challenge to a public contract award. It can be used to argue that a government decision was improperly influenced by political pressure from an MP with a vested financial interest.

Part III: Application to COCOO Doctrines

This model is designed to provide the evidentiary basis for our political and legal influencing strategies.

Mind Map Doctrine	Application of the Register of Interests Model
Challenge Discrpower / JR2COURT	Evidence of an MP’s conflict of interest is a powerful tool to challenge the legitimacy of a discretionary government decision they may have influenced, forming a key plank of a judicial review submission¹¹¹¹¹¹¹¹¹¹.
PTW (Political Time Window)	Knowing an MP has a conflict allows us to time our interventions. We can release our findings or file a complaint just before a critical vote or debate in which that MP is involved, maximizing political pressure and media attention²²²².
Lobby Tools	This register is a primary intelligence “Lobby Tool”³³³³³³³³. It tells us which MPs to avoid due to conflicts and which may be receptive to our arguments because their declared interests do not clash with our objectives.
Noisefilter	An MP’s speech is political noise. The Register of Interests is the filter that allows us to understand the potential financial motivations behind their words, separating their public position from their private interests⁴⁴⁴⁴.
FOC DAM (Find Other Claimants, Monetize Damages)	If an MP’s biased actions have harmed one entity, this evidence can be used to build a broader case, arguing that a whole class of companies or individuals was disadvantaged, thus expanding the pool of potential claimants⁵⁵⁵⁵.

Jun

2025

www.companieshouse.find.company.info

SEARCHLINKS

Full URL: https://find-and-update.company-information.service.gov.uk/advanced-search

Strategic Imperative

Companies House is the primary source for factual, verifiable data on every registered company in the UK. It is the starting point for almost all of our UK-based investigations. While other tools provide context and intelligence, Companies House provides the official, undeniable record of a company’s existence, its directors, its financial state, and its ownership structure.

This platform is mission-critical for:

Uncovering “Stealth Consolidation”: This is the primary tool for identifying networks of companies in the same market segment that are controlled by a common directorate, a key indicator of a stealth consolidation strategy. ²²²²²²²
MATOIPO (Merger, Acquisition, Takeover…) Analysis: Verifying the legal status, directors, and ultimate beneficial owners (Persons with Significant Control) of any UK company involved in a transaction is a fundamental due diligence step.
“Benchmarking” and Competitor Analysis: The platform’s ability to search by industry code allows us to generate comprehensive lists of all registered competitors in a specific market, forming the basis of any credible market analysis. ³
Originating Cases: Identifying companies with red flags (e.g., overdue accounts, rapid changes in directors) can be a “Simple Indicator” of distress, presenting an opportunity for intervention.

Part I: The Search Platform’s Rules & Functionality

The power of the Companies House Advanced Search lies in its highly specific and combinable filters. It does not use complex Boolean operators but relies on structured field searching.

Primary Search Fields:
- Company name: Searches for a company name. It supports “contains,” “starts with,” and excluding keywords.
- Company number: The most precise way to find a specific company.
Key Filtering Options:
- Location: Search by registered office address or postcode.
- Company status: A critical filter. Allows you to include or exclude Active, Dissolved, Open, Closed, etc.
- Company type: Filter by legal form (e.g., Private limited company, Public limited company (PLC)).
- Nature of business (SIC code): This is an exceptionally powerful filter. It allows searching for companies registered under specific Standard Industrial Classification (SIC) codes, enabling precise sectoral analysis. ⁴
- Incorporation dates: Filter for companies created within a specific time frame.
- Dissolved dates: Filter for companies dissolved within a specific time frame.
Information Available on Company Profiles: Once a company is selected, its profile provides access to:
- Filing history: A complete, chronologically ordered list of all documents ever filed.
- People: A list of all current and former officers (directors, secretaries) and Persons with Significant Control (PSCs). This is our gateway to the beneficial ownership data.
- Charges: A register of any outstanding charges or mortgages against the company’s assets.

Part II: The COCOO Strategic Search Model for Companies House

This protocol provides a systematic workflow for any investigation involving a UK entity.

Phase 1: The Sectoral Sweep Protocol

This protocol is used to map an entire market segment.

Step 1.1: Identify the SIC Code: Determine the correct SIC code for the industry you are investigating.
Step 1.2: Execute the Search: On the Advanced Search page, enter the SIC code into the Nature of business field. Ensure the Company status filter is set to Active.
Step 1.3: Extract the Competitor List: The result is a comprehensive list of every active company operating in that specific market niche in the UK. This list is the foundation for any “Benchmarking” or competitor analysis. ⁵

Phase 2: The “Stealth Consolidation” Network Mapping Protocol

This protocol is designed to uncover hidden ownership networks.

Step 2.1: Initial Target Analysis: For a primary target company, navigate to its profile and click on the People tab.
Step 2.2: Extract Director and PSC Names: Systematically record the names of all current directors and Persons with Significant Control.
Step 2.3: Reverse-Engineer the Network: Click on the name of a specific director. This will take you to a page listing all other companies where that individual currently holds or has held an appointment.
Step 2.4: Cross-Reference and Map: Repeat Step 2.3 for all directors and PSCs. Cross-reference the lists of their appointments. If multiple directors from different “competing” companies (identified in Phase 1) all have appointments at the same parent company or investment fund, you have found direct evidence of a common control structure. This is the “smoking gun” for “Stealth Consolid”. ⁶⁶⁶⁶

Phase 3: The “Red Flag” Analysis Protocol

Step 3.1: Monitor Filing History: For a target company, review their Filing history. Look for red flags such as:
- Overdue accounts or Overdue confirmation statement. This is a “Simple Indicator” of administrative or financial distress.
- A high frequency of Director resignation and Appointment of director filings, which can indicate instability.
Step 3.2: Check for Distress Signals: Navigate to the Charges tab. A large number of recently filed charges can indicate that the company is highly leveraged and potentially in financial trouble.

Part III: Application to COCOO Doctrines

This model directly executes our strategic imperatives as laid out in the mind maps.

Mind Map Doctrine	Application of the Companies House Model
Stealth Consolid	The “Network Mapping Protocol” (Phase 2) is the primary, systematic method for proving “Stealth Consolidation” in the UK. It directly uncovers the common control structures that are not visible at the surface level. ⁷⁷⁷⁷
Benchmarking / Competitor Analysis	The “Sectoral Sweep Protocol” (Phase 1) is the essential first step for any market analysis, providing the complete list of competitors needed to benchmark our targets. ⁸
MATOIPO Analysis	This platform is the definitive source for verifying the legal status, directorship, and PSCs of any UK target or acquirer in a transaction, forming the core of our due diligence.
Noisefilter	A company’s press release is noise. Their official filing history, director appointments, and PSC register on Companies House are the verifiable, legally significant signals we use to filter that noise. ⁹⁹⁹⁹
Simple Indicators	The “Red Flag” Analysis (Phase 3) is designed to find “Simple Indicators” of corporate distress or instability, such as overdue accounts, which allow us to qualify potential targets for intervention. ¹⁰¹⁰¹⁰¹⁰

Jun

2025

www.infosubvenciones.es

SEARCHLINKS

Full URL: https://www.infosubvenciones.es/bdnstrans/GE/es/index

Strategic Imperative

The National Subsidies Database is the definitive record of non-tender public funding in Spain. For COCOO, this intelligence is vital for mapping the financial relationships between the state and the private sector. A company’s reliance on public subsidies is a potential vulnerability, and the government’s pattern of giving subsidies reveals its true policy priorities.

This platform is mission-critical for:

Identifying Competitor Weaknesses: A competitor that is heavily reliant on public subsidies can be vulnerable. If we can demonstrate, using Violation Tracker, that this company is non-compliant with the very regulations the subsidy is meant to uphold (e.g., receiving environmental subsidies while committing environmental violations), we create a powerful case for the subsidy to be revoked.
Challenging State Aid Decisions: This database provides the raw data to identify potential illegal State Aid. If a subsidy provides a selective advantage to one company over its competitors, it may be open to a formal challenge with the EC, a core COCOO strategy.
Uncovering “Enforcement Gaps”: We can identify situations where the government is subsidizing companies that are actively working against its own stated policies (e.g., giving innovation grants to a firm engaged in anti-competitive practices). This contradiction is a clear “Enforcement Gap” that we can exploit.
Informing our “Challenge Discretionary Power” Doctrine: The decision to award a grant is a discretionary act. This database provides the evidence needed to question the basis for that act, especially if the beneficiary is a high-risk entity or linked to decision-makers.

Part I: The Search Platform’s Rules & Functionality

The platform is a filter-based search engine that allows for highly specific queries.

No Complex Operators: Like other Spanish government portals, the search relies on filling structured fields rather than using complex Boolean operators.
Key Search Fields (Criterios de búsqueda):
- NIF: The most precise way to search for a specific beneficiary, using their tax ID.
- Beneficiario (Beneficiary): Searches for a company or individual by name.
- Órgano convocante (Granting Body): A critical filter to see all grants awarded by a specific ministry, regional government, or public body.
- Título de la convocatoria (Title of the Call): A keyword search for the name or subject of the grant program itself (e.g., digitalización, sostenibilidad).
- Región: Filters grants by the autonomous community.
- Fecha (Date): Filters for grants awarded within a specific time period.
- Importe concedido (Amount granted): Allows filtering for subsidies above or below a certain value.

Part II: The COCOO Strategic Search Model for the Subsidies Database

This protocol provides a workflow for turning subsidy data into strategic leverage.

Phase 1: Adversary & Sectoral Intelligence Gathering

Step 1.1: Competitor Subsidy Audit: For any key competitor or adversary, run a search for their NIF or name in the Beneficiario field. The goal is to create a complete dossier of all public subsidies they have received. Quantify their level of dependency on public funds.
Step 1.2: Thematic Grant Analysis: Use the Título de la convocatoria keyword search to find all grants related to a specific policy area (e.g., “artificial intelligence,” “renewable energy”). This identifies all companies being state-funded to operate in that space, revealing the government’s chosen “champions.”
Step 1.3: Granting Body Analysis: Use the Órgano convocante filter to analyze the grant-giving patterns of a specific public body. Are they consistently awarding grants to the same set of companies? This can be an indicator of a closed ecosystem or potential bias.

Phase 2: The “Hypocrisy & Contradiction” Protocol

This is the core protocol for generating leverage from this platform.

Step 2.1: Identify the Subsidy: From the audit in Step 1.1, identify a significant subsidy received by a target company. Note the purpose of the grant (e.g., for environmental improvements, for worker training).
Step 2.2: Find the Contradictory Violation: Immediately run the beneficiary company through our other intelligence tools, primarily Violation Tracker UK (and its Spanish equivalents). The goal is to find a direct contradiction. For example:
- The company received a large environmental grant, but Violation Tracker shows they were recently fined for pollution.
- The company received a grant for job creation, but their financial reports (from InfoCIF) show significant layoffs.
Step 2.3: Document the Evidence: Compile a simple but powerful dossier containing two pieces of evidence: the official record of the subsidy from this portal, and the official record of the violation.

Phase 3: Strategic Action

Step 3.1: Challenge the Subsidy: The documented contradiction is grounds for a formal complaint to the granting body and potentially to an anti-fraud office. The argument is that the beneficiary has obtained public funds under false pretenses or has violated the terms of the subsidy.
Step 3.2: Create Leverage Against the Beneficiary: This evidence can be used as leverage in a separate legal dispute. A company facing the potential revocation of its public subsidies may be more willing to settle another matter on favorable terms.

Part III: Application to COCOO Doctrines

This model directly executes our strategies for creating leverage and challenging public decisions.

Mind Map Doctrine	Application of the National Subsidies Database Model
Challenge Discrpower / Enforcement Gap	The “Hypocrisy & Contradiction” protocol (Phase 2) is the primary mechanism for identifying a clear “Enforcement Gap”. We use this to “Challenge the Discretionary Power” of the body that awarded the grant, questioning their due diligence.
State Aid (EC/CMA)	This database is the starting point for identifying potentially illegal State Aid in Spain. A grant that appears to give a selective advantage to one company over others can be flagged for a potential complaint to the European Commission.
Benchmarking / Competitor Analysis	The Competitor Subsidy Audit (Step 1.1) is a key part of our competitor analysis. Understanding a rival’s reliance on state funding is a critical indicator of their true financial health and political connections.
Noisefilter	A company’s public statements about their commitment to sustainability are just noise. The record of them receiving environmental subsidies while also being fined for pollution is the signal that matters.
PTW (Political Time Window)	The discovery of a major contradiction (e.g., a politically connected company receiving large grants while violating the law) has maximum impact if revealed during a sensitive time, such as a debate on the budget of the granting ministry.

Jun

2025

www.contrataciondelestado.es

SEARCHLINKS

Full URL: https://contrataciondelestado.es/wps/portal/licitaciones

Strategic Imperative

The PLACSP is the definitive central portal for public sector tenders in Spain². Our mastery of this platform is fundamental to generating revenue and executing several core strategies. It allows us to:

Find Tender Opportunities: The platform is the direct route to finding high-value and low-value public contracts for which we can bid³.
Reverse-Engineer Winning Bids: By analyzing past contract awards, we can identify successful competitors, understand their pricing, and deconstruct their winning strategies, creating a “winner’s profile” to benchmark against⁴.
Identify Incumbent Weaknesses: We can use the platform to identify the current holders of contracts. By cross-referencing these incumbents with our other intelligence tools (e.g., Violation Tracker, InfoCIF), we can uncover financial or compliance weaknesses that make them a risky choice for a public body, thereby strengthening our own bid⁵⁵⁵⁵.
Originate Unsolicited Proposals (USPs): Analyzing patterns of procurement—such as a department repeatedly issuing small, fragmented contracts for a single service—allows us to identify chronic inefficiencies⁶. This is a direct trigger for a COCOO USP, where we propose a more efficient, integrated solution⁷.
Challenge Flawed Awards: The platform provides the official record needed to challenge a contract award, for instance, by showing the process was unfairly skewed towards a competitor or that the winning bidder poses a significant, documented risk⁸.

Part I: The Search Platform’s Rules & Functionality

The platform’s power lies in its extensive and granular filtering capabilities. The Búsqueda de licitaciones (Tender Search) form is our primary interface.

No Complex Operators: The search functions primarily through structured filters, not complex Boolean operators in a single text box.
Key Search Filters:
- Objeto del Contrato (Object of the Contract): A full-text search for keywords describing the contract (e.g., mediación, consultoría, análisis de datos).
- Estado de la Licitación (Tender Status): This is the most critical filter for strategic timing. Key statuses include:
  - Anuncio Previo: Early warning of a future tender.
  - Publicada: An open, active tender to bid on.
  - Adjudicada: A contract that has been awarded. This is essential for competitor analysis.
  - Resuelta: A contract that has been completed.
- Tipo de contrato (Type of Contract): Allows filtering for Servicios (Services), Suministros (Supplies), etc.
- Procedimiento de adjudicación (Award Procedure): Filters by how the contract is awarded (e.g., Abierto – Open, Restringido – Restricted, Negociado – Negotiated).
- Adjudicatario (Awardee/Winner): A powerful filter to search for all contracts won by a specific company. Requires the company’s NIF (tax ID).
- Importe (Value): Allows filtering by the estimated or final contract value.
- Codes CPV: Uses the Common Procurement Vocabulary codes to find tenders in specific, standardized categories. This is more precise than keyword searching⁹.

Part II: The COCOO Strategic Search Model for PLACSP

This protocol provides a systematic workflow for dominating the public procurement process.

Phase 1: Opportunity Finding & Early Warning

Step 1.1: Establish Saved Searches: Using the advanced search form, create and save searches for our core service areas using a combination of keywords in the Objeto del Contrato and relevant CPV codes¹⁰. Set the Estado to Publicada for active opportunities.
Step 1.2: Pre-Tender Intelligence: Run a separate, recurring search with the Estado filter set to Anuncio Previo (Prior Information Notice)¹¹. This identifies opportunities months in advance, giving us time to engage with the buyer and shape the requirements before the tender is even published¹²¹²¹²¹².

Phase 2: The “Incumbent/Competitor Dossier” Protocol

This protocol is for analyzing the competition before and after bidding.

Step 2.1: Identify the Incumbent/Winner: For a relevant tender (either a future opportunity or one we have bid on), find the previous or current contract holder. Use the Adjudicatario filter with the competitor’s NIF to find all contracts they have ever won, or search by keywords and filter for Adjudicada status¹³¹³¹³¹³.
Step 2.2: Analyze the Winning Bid: For awarded contracts, download the documento de adjudicación (award document). This will contain the final contract value and may include details about the winning proposal¹⁴.
Step 2.3: Conduct External Intelligence Sweep: Take the incumbent/winner’s name and NIF and run them through our full intelligence arsenal (InfoCIF, Violation Tracker, OEPM). The goal is to find disqualifying information: a history of environmental violations, poor financial health, or a lack of the necessary IP for the contract¹⁵¹⁵¹⁵¹⁵.

Phase 3: Strategic Action: The Intelligence-Led Bid & Challenge

Step 3.1: Shape the Tender: During the pre-market engagement phase identified in Step 1.2, subtly provide information to the buyer that highlights the weaknesses of the incumbent (discovered in Step 2.3) and frames the tender requirements in a way that favours COCOO’s unique strengths¹⁶.
Step 3.2: Submit a Superior Bid: Our final bid must not only meet the specifications but also explicitly address the unstated risks posed by competitors, using the publicly available data we have gathered to substantiate our claims of being a lower-risk, higher-value partner¹⁷.
Step 3.3: Prepare to Challenge the Award: If a contract is awarded to a high-risk competitor we have profiled, we immediately file a formal query or legal challenge. The challenge will be based on the public data we have compiled, questioning whether the authority has fulfilled its due diligence and value-for-money obligations¹⁸¹⁸¹⁸.

Part III: Application to COCOO Doctrines

This model directly executes our commercial strategies as laid out in the mind maps.

Mind Map Doctrine	Application of the PLACSP Portal Model
Tender / USP	The entire model is designed to win tenders¹⁹. The analysis of procurement patterns (e.g., fragmented contracts) directly enables the creation of data-driven USPs that solve a buyer’s unstated efficiency problem²⁰.
Benchmarking / Competitor Analysis	The “Incumbent/Competitor Dossier” protocol (Phase 2) is a pure application of this doctrine, using official award data to benchmark against successful bidders and identify their weaknesses²¹.
Challenge Discrpower	The “Prepare to Challenge the Award” step (3.3) is a direct execution of this principle, using evidence to question the discretionary power of a public body in its choice of contractor²².
Noisefilter	The platform allows us to filter the “noise” of the market and focus on confirmed, funded public sector needs, ensuring our business development efforts are targeted at real, winnable opportunities²³.
Simple Indicators	A public body repeatedly awarding contracts to the same high-risk provider, despite their known compliance failures (found via Violation Tracker), is a “Simple Indicator” of a flawed procurement process that is ripe for a systemic challenge²⁴.

Jun

2025

www.boe.es/seccion/edictos_concursales

SEARCHLINKS

Full URL: https://www.boe.es/seccion/edictos_concursales

Strategic Imperative

The BOE is the Spanish government’s official journal of record. The notices published in its insolvency section (edictos concursales) are not just announcements; they are legally binding acts that trigger deadlines and define the status of a company. For COCOO, this platform is a primary source for identifying companies in acute financial distress, which presents a range of strategic opportunities.

This platform is mission-critical for:

Originating Monetizable Assets: The insolvency of a company often forces its valuable legal claims onto the market. ¹ Our research confirms that “purchasing insolvency claims” is a core activity for major litigation funders. ² This portal allows us to identify these situations at the earliest possible moment.
FOC DAM (Find Other Claimants, Monetize Damages): An insolvency notice is a clear signal of harm. By identifying the insolvent entity, we can then investigate its business relationships to find other affected parties (e.g., suppliers with unpaid invoices, customers with unfulfilled orders) and aggregate their claims. ³
Competitor Analysis & Market Restructuring: The failure of a competitor, officially confirmed in the BOE, is a significant market event. It provides an opportunity to analyze the failing company’s assets (including legal claims, IP, and contracts) which may become available for purchase from the insolvency administrator.

Part I: The Search Platform’s Rules & Functionality

The BOE’s search functionality is powerful but requires a methodical approach. It combines structured filters with full-text search.

Primary Search Bar (Buscar en 'Edictos concursales'): This is a full-text search bar. It will search the entire text of the published notices. This is extremely powerful for finding specific company names, director names, or case numbers.
- It supports exact phrase searching using double quotation marks (" ").
- It supports Boolean operators: Y (AND), O (OR), NO (NOT).
Date Filter (Fecha de Publicación): Allows searching for notices published on a specific date or within a date range. This is essential for ongoing monitoring.
Advanced Filters (Búsqueda avanzada): This opens up more precise filtering options:
- Órgano emisor (Issuing body): Allows filtering by the specific court handling the insolvency (e.g., Juzgado de lo Mercantil nº 1 de Madrid).
- Departamento (Department): Allows filtering by the relevant ministry, which in this case is typically the Ministry of Justice (Ministerio de Justicia).

Part II: The COCOO Strategic Search Model for the BOE

This protocol provides a workflow for systematically exploiting the intelligence within the BOE.

Phase 1: Proactive Monitoring & Forensic Search

Step 1.1: Daily Watchlist Search: Our first action each day will be to run our “Adversary & Supply Chain Watchlist” through the main search bar using exact phrase matching (e.g., "Nombre de la Empresa S.A."). This ensures we are the first to know if a key entity has entered insolvency.
Step 1.2: Thematic Keyword Search: On a weekly basis, conduct broader text searches for keywords related to our target sectors. This can uncover smaller, unknown companies within that sector that are entering insolvency.
Step 1.3: Court-Specific Monitoring: If our intelligence suggests a particular region is experiencing economic distress, we can use the Órgano emisor filter to monitor all insolvency notices coming from the commercial courts in that specific province.

Phase 2: The Asset Identification Protocol

Step 2.1: Extract Key Data: Once a relevant insolvency notice (edicto) is found, open the official PDF. The crucial data points to extract are:
- The full name and NIF of the insolvent company.
- The court and case number (número de autos).
- The name and contact details of the appointed administrador concursal (insolvency practitioner).
- The deadline for creditors to communicate their claims.
Step 2.2: Launch Intelligence Cross-Referencing: Immediately take the company’s name and NIF and run it through our other intelligence platforms (InfoCIF, OEPM, CNMV). The goal is to build a rapid profile of the company’s assets before insolvency. We are specifically looking for:
- Evidence of ongoing litigation (from news searches or past financial reports).
- Valuable patents or trademarks (from the OEPM).
- Significant unpaid receivables from large, solvent companies.
Step 2.3: Identify the Monetizable Claim: The synthesis of the BOE notice and the cross-referenced intelligence allows us to identify the specific, high-value legal asset (e.g., “a patent infringement claim against Competitor X,” “a breach of contract suit against Supplier Y”).

Phase 3: Strategic Engagement

Step 3.1: Package the Opportunity: Prepare a concise dossier on the identified legal asset, including the evidence of its existence and an initial valuation.
Step 3.2: Formulate the USP for the Administrator: Craft an Unsolicited Proposal (USP) for the appointed insolvency practitioner. ⁴ The proposal will offer a clear path to monetization that serves their duty to the creditors, such as facilitating the outright sale of the claim or arranging non-recourse funding for its pursuit. ⁵⁵⁵

Part III: Application to COCOO Doctrines

This model directly executes our strategies for originating high-value, complex cases.

Mind Map Doctrine	Application of the BOE Insolvency Portal Model
FOC DAM / Find new evidence to be monetised	This portal is the primary source for finding legal claims held by insolvent estates. ⁶ These are, by definition, assets that must be monetized, making them ideal targets for our case origination strategy. ⁷
USP (Unsolicited Proposal)	The entire Strategic Engagement protocol (Phase 3) is a playbook for creating a compelling USP, not for the company itself, but for the insolvency practitioner who controls its assets, offering a sophisticated solution to their problem. ⁸
Stealth Consolid	The insolvency of a smaller player in a market can be a trigger for a larger competitor to acquire its assets on the cheap. By monitoring the BOE, we can anticipate these moves and analyze them for anticompetitive effects. ⁹
Noisefilter	Market rumors of a company’s financial trouble are just noise. ¹⁰ An official insolvency notice in the BOE is a definitive, legally significant signal that demands immediate and focused action.
Benchmarking / Competitor Analysis	The official declaration of a competitor’s insolvency is a final, critical data point in any competitor analysis, confirming their exit from the market and the potential availability of their assets and market share.