COCOO CASES

www.publicadorconcursal.es

                                                                   

Full URL: https://www.publicadorconcursal.es/

Strategic Imperative

The Publicador Concursal is the official state platform for all notices related to insolvency and bankruptcy proceedings in Spain. Its strategic value to COCOO is immense and directly supported by our intelligence. Our research shows that a key activity for sophisticated litigation funders is “purchasing insolvency claims”. 1 This portal is our direct window into that marketplace. By monitoring new insolvency proceedings, we can identify valuable legal assets (such as unresolved legal claims held by the insolvent company) that can be acquired from the insolvency practitioner.

 

This platform is therefore mission-critical for:

  • Originating Monetizable Assets: It allows us to proactively identify legal claims that can be purchased outright or funded, aligning with the business models of funders like Bench Walk Advisors and Fortress Investment Group. 222
  • Competitor Destabilization: Identifying a key competitor or supplier entering insolvency provides a “Political Time Window” (PTW) to act, either by acquiring their valuable assets/claims or by positioning COCOO as a mediator in the resulting supply chain disruption. 33
  • USP (Unsolicited Proposal) to Insolvency Practitioners: We can approach the appointed administrador concursal (insolvency practitioner) with a USP to value and monetize the estate’s legal claims, offering a solution to generate value for creditors. 444

Part I: The Search Platform’s Rules & Functionality

The platform is a straightforward, filter-based search tool. Precision comes from using the correct identifiers and understanding the process.

  • Primary Search Fields:
    • Nombre/Razón social (Name / Company Name): Searches for the name of the insolvent individual or company.
    • NIF / Otro doc. (Tax ID / Other Doc.): The most precise way to search, using the entity’s unique Spanish tax identification number.
    • Provincia (Province): Allows filtering by geographic region, which is useful for identifying clusters of insolvency in a specific area.
  • Key Filters:
    • Tipo de resolución (Type of resolution): This is a critical filter for understanding the stage of the insolvency process. Key stages include the declaration of insolvency, the appointment of the insolvency administrator, and the plan for liquidation or agreement.
  • Access to Information: The search results provide a summary of the notice. Clicking on a result provides access to the official notice (the edicto), which contains details of the court, the case number, the insolvency administrator appointed, and key deadlines for creditors to present their claims.

Part II: The COCOO Strategic Search Model for the Publicador Concursal

This protocol provides a systematic workflow for identifying high-potential opportunities.

Phase 1: Proactive Monitoring & Targeted Search

  • Step 1.1: Adversary & Supply Chain Watchlist: We will maintain a list of key competitors, strategic suppliers, and other relevant companies in our target sectors. This list will be run through the Publicador Concursal search on a weekly basis to catch any new insolvency filings immediately.
  • Step 1.2: Sectoral Distress Monitoring: On a monthly basis, we will conduct searches using the Provincia filter for provinces with a high concentration of our target industries. A spike in insolvency notices in a specific region and sector can be a “Simple Indicator” of widespread market distress and opportunity. 5

Phase 2: The Opportunity Qualification Protocol

  • Step 2.1: Initial Triage: Once a potentially interesting insolvent company is identified, the first step is to retrieve the official notice and identify the appointed insolvency administrator and the court.
  • Step 2.2: Corporate Intelligence Deep Dive: Immediately conduct a full corporate intelligence workup on the insolvent company using our other tools (InfoCIF, OEPM, etc.). The goal is to identify their potential assets, particularly valuable legal claims they may have been pursuing before insolvency (e.g., claims against larger companies for breach of contract).
  • Step 2.3: Identify High-Value Claims: Look for evidence of large, unresolved commercial disputes, unpaid debts from major customers, or potential claims against former directors. These are the “legal assets” we can monetize. 6

Phase 3: Strategic Action & USP Formulation

  • Step 3.1: Approach the Insolvency Practitioner: Once a valuable potential claim is identified, we will approach the appointed insolvency practitioner. Practitioners have a duty to maximize value for the estate’s creditors. 7
  • Step 3.2: Craft the USP: We will present a formal USP. The proposal will not just be to “buy the claim” but to offer a sophisticated solution. We can offer:
    1. To facilitate a non-recourse funding agreement with a litigation funder to pursue the claim, taking the cost and risk away from the insolvent estate. 8888
    2. To facilitate an outright purchase of the claim by a specialized firm, providing immediate liquidity to the creditors. 999999999
    3. To act as COCOO, providing the expert management to package the claim and run the process, securing a fee for our services.

Part III: Application to COCOO Doctrines

This model is designed to directly execute our most advanced case origination strategies.

Mind Map Doctrine Application of the Publicador Concursal Model
FOC DAM / Find new evidence to be monetised This is the primary application. The portal is a direct source of legal claims (evidence) that are, by definition, held by a party (the insolvent estate) that needs to monetize them. We find the evidence and the motivated seller in one place. 1010
USP (Unsolicited Proposal) The entire Strategic Action protocol (Phase 3) is a playbook for crafting a high-value USP to an insolvency practitioner, offering a sophisticated financial solution rather than just a legal service. 11111111
PTW (Political Time Window) The insolvency of a major employer in a specific region creates an immediate political and economic crisis. This is a PTW that allows us to approach regional authorities with proposals to save jobs by efficiently monetizing the company’s assets, including its legal claims. 12121212
Noisefilter The portal allows us to filter the “noise” of market rumors. A company rumored to be in trouble is just gossip; a company appearing on the Publicador Concursal is a confirmed, actionable opportunity. 13131313
Acquiring Claims (as per Litigation Finance market) This model directly operationalizes the strategies of major legal finance players who explicitly state they are “purchasing insolvency claims”. We use this tool to find the very assets they are looking for, positioning COCOO as a valuable originator. 14
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www.consultas.oepm.es

                                                                   

Full URL: https://consultas.oepm.es/

Strategic Imperative

The OEPM portal is our primary tool for investigating the intellectual property landscape in Spain. The trademarks, patents, and designs registered by a company are a direct reflection of its commercial strategy and technological capabilities. This intelligence is fundamental for:

  • Identifying Litigation-Dependent Assets: Some firms’ entire business model is based on monetizing IP through litigation. 111 The OEPM portal allows us to identify these assets and the companies that hold them, presenting opportunities for us to facilitate funding, purchase, or a strategic challenge.
  • Competitor Analysis: A company’s patent and trademark filings are a forward-looking indicator of its new products, target markets, and strategic direction. This is a key input for our “Benchmarking” and “Porter” analysis frameworks. 22
  • Evidence for Competition Cases: IP rights can be used anticompetitively. For example, a dominant company might file a dense web of defensive patents to block new entrants (“patent thickets”) or engage in sham litigation. Evidence of such behaviour from the OEPM can be used to build an abuse of dominance case.
  • Informing MATOIPO Analysis: In any merger or acquisition, the IP portfolio is often a key asset. 3 Analyzing the target’s and acquirer’s IP on the OEPM portal is a critical part of our due diligence to assess the true value and risks of the transaction.

Part I: The Search Platform’s Rules & Functionality

The OEPM portal is divided into sections for different types of IP. The key is to use the “Búsqueda por campos” (Field Search) or “Búsqueda avanzada” (Advanced Search) options within each section for maximum precision.

  • Platform Structure: The portal is split into distinct databases for:

    • Signos Distintivos (Trademarks and Tradenames): For brand-related intelligence.
    • Invenciones (Inventions): For patents and utility models.
    • Diseños (Designs): For industrial designs.
  • Key Search Fields (Búsqueda por campos):

    • Solicitante / Titular (Applicant / Owner): The most important field. Allows searching for the company or individual that owns the IP.
    • Denominación (Name/Title): Searches for the name of the trademark or the title of the patent.
    • Clasificación (Classification): Allows searching by specific classification codes (e.g., Vienna Classification for logos, International Patent Classification for inventions). This is a powerful tool for finding all IP within a specific technological or commercial area.
    • Fechas (Dates): Allows filtering by application date, registration date, or expiration date.
    • Agente (Agent): Allows searching for the law firm or agent that filed the application, which can help map relationships.
  • Search Syntax:

    • The search engine supports Boolean operators (Y for AND, O for OR, NO for NOT).
    • It also allows for wildcard characters (* for multiple characters, ? for a single character).
    • Phrase searching using double quotation marks (" ") is supported for exact matches.

Part II: The COCOO Strategic Search Model for the OEPM

This protocol provides a systematic workflow for turning IP data into actionable evidence.

Phase 1: Adversary and Sector Profiling

  • Step 1.1: Adversary IP Audit: For any target company or legal adversary, conduct a comprehensive search using their name in the Solicitante / Titular field across all three databases (Trademarks, Inventions, Designs). The goal is to build a complete dossier of their registered IP assets in Spain.
  • Step 1.2: Thematic Technology Search: To understand a technology landscape, use the “Advanced Search” in the Inventions database. Search using relevant Classification Codes (IPC) or keywords in the patent titles/abstracts. This will reveal all companies patenting in a specific area, identifying the key innovators and potential licensing targets.

Phase 2: The “Strategic Intent” Analysis Protocol

  • Step 2.1: Analyze Filing Velocity: For a target company, use the date filters to analyze their rate of patent and trademark applications over time. A sudden acceleration in filings in a new technology area can be a “Simple Indicator” of a major strategic pivot or a new product launch. 4
  • Step 2.2: Map Brand Architecture: In the Trademarks database, analyze the different brands a single company owns. Are they launching sub-brands to target new market segments? Are they registering defensive trademarks to block competitors? This reveals their commercial strategy.
  • Step 2.3: Identify “Non-Practicing Entities” (NPEs): Look for entities with a significant number of patents but no corresponding commercial products (which can be checked via general web searches and company reports). These entities may be “patent trolls” whose business model is based purely on litigation. 5 These are prime targets for our work, as we can potentially partner with the companies they are targeting.

Phase 3: Intelligence Synthesis & Strategic Action

  • Step 3.1: Identify Potential for Monetization: Based on the NPE analysis (Step 2.3) or identifying companies with valuable but under-utilized patents, we can build a case for an Unsolicited Proposal (USP). We can approach a litigation funder (identified from our research) with a portfolio of patents ripe for an enforcement action, with COCOO positioned to manage the process. 6666
  • Step 3.2: Build Evidence for Competition Complaints: If we identify a dominant company aggressively filing patents around a competitor’s core technology, this can be used as evidence of anticompetitive intent in a complaint to the CNMC.
  • Step 3.3: Due Diligence for Tenders: When bidding for a public contract, especially in a technology-driven sector, we will perform an IP audit on all major competitors. A competitor whose bid relies on technology that infringes on a third party’s patent represents a significant risk to the public body, a weakness we can highlight in our own proposal.

Part III: Application to COCOO Doctrines

This model is designed to directly execute key strategies from our mind maps.

Mind Map Doctrine Application of the OEPM Portal Model
USP (Unsolicited Proposal) & FOC DAM The “Strategic Intent” Analysis (Phase 2) is a direct mechanism for originating USPs. 7 By identifying valuable IP assets, we can create a proposal for a litigation funder to monetize them, with COCOO managing the legal work.
Benchmarking / Competitor Analysis The Adversary IP Audit (Step 1.1) provides a clear benchmark of a competitor’s technological capabilities and brand strategy, feeding directly into our market analysis. 8
Noisefilter A company’s press releases about “innovation” are just noise. Their patent filings on the OEPM are the verifiable signal. 9 This allows us to filter PR from genuine technological investment.
MATOIPO Analysis An IP audit is a non-negotiable step in analyzing any M&A deal. 10 Does the target really own the “crown jewel” patents the acquirer is paying for? Are they about to expire? Are they being challenged? This analysis provides critical leverage.
Stealth Consolid While less direct, a single entity or fund acquiring patents from multiple smaller players in a specific tech niche can be an indicator of a “roll-up” strategy, a form of technological consolidation that precedes corporate M&A. 11
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www.transparencia.gencat

                                                                   


Full URL: https://transparencia.gencat.cat/ca/registre-de-grups-d-interes/inici/

Strategic Imperative

The Catalan Interest Group Register provides a transparent record of entities attempting to influence public policy-making and administration within the Generalitat de Catalunya. Mastering this tool is essential for any COCOO operation with a nexus in Catalonia. It allows us to map the political landscape, identify adversaries’ strategic objectives, and uncover leverage points to support our cases.

This platform is specifically designed to execute our core doctrines at a regional level:

  • Challenge Discretionary Power: We can use this register to question the impartiality of regional administrative decisions by documenting the lobbying activities that preceded them1111.
  • PTW (Political Time Window): Monitoring lobbying at the regional level allows us to identify and act within moments of maximum political sensitivity in Catalonia, amplifying our impact2.
  • USP (Unsolicited Proposal): Identifying a problem that entities are consistently lobbying the Catalan government about, without resolution, is a direct trigger for a COCOO Unsolicited Proposal (USP)3333.
  • Lobby Tools: This register is a primary “Lobby Tool”4, providing the intelligence needed to build our own effective public affairs campaigns directed at the Catalan government.

Part I: The Search Platform’s Rules & Functionality

The platform is a filter-based search system. Effective use requires understanding its specific data fields.

  • Cercador del Registre (Register Search): This is the main search interface.
  • Primary Search Fields:
    • Nom de la organització (Organisation Name): Searches for a specific company or association name.
    • NIF: Searches by the entity’s unique Spanish tax identification number for a precise match.
  • Key Filtering Options:
    • Categories: This allows filtering by the type of entity (e.g., companies, trade associations, NGOs). This is crucial for understanding who is lobbying on an issue.
    • Àmbits d'interès (Fields of Interest): A powerful filter that allows searching for all organisations that have registered an interest in a specific policy area (e.g., “Contracts of the public sector,” “Environment,” “Competition,” “Taxation”).
    • País (Country): Filters registered entities by their country of origin.
  • Data Available on Profiles: Once an entity is selected, its profile contains detailed information, including:
    • Contact information and responsible individuals.
    • Financial information, including estimates of lobbying expenditure.
    • A list of the associations or networks they belong to.
    • Crucially, some profiles may list meetings with public officials, although this is less standardized than on other platforms.

Part II: The COCOO Strategic Search Model for the Catalan Register

This protocol provides a systematic workflow for any case with a Catalan dimension.

Phase 1: Proactive & Case-Specific Targeting

  • Step 2.1: Adversary and Sector Analysis: In any case involving a company with significant operations in Catalonia, its name and NIF must be searched on this register. We must also identify the key regional trade associations and run searches on them.
  • Step 2.2: Thematic Monitoring: This is the most powerful proactive use of the tool. Use the Àmbits d'interès filter to conduct searches on topics central to our mission, such as:
    • Contractes del sector públic (Public sector contracts)
    • Competència (Competition)
    • Medi ambient (Environment) This will generate a complete list of every entity actively trying to influence policy in these areas within Catalonia.

Phase 2: The Influence Mapping Protocol

  • Step 2.1: Identify Key Players: From the thematic search, identify the companies and associations with the highest declared lobbying budgets or those who are most active. These are the key market shapers.
  • Step 2.2: Analyze Affiliations: On a target entity’s profile, carefully review the networks and federations they belong to. This helps map coalitions and understand how influence is consolidated and exercised through umbrella groups.
  • Step 2.3: Cross-Reference with other Data: Correlate the lobbying activity with our other intelligence. If a company undergoing “Stealth Consolidation” 5 is also lobbying the Catalan government to relax market entry regulations, we have found a powerful link between their corporate and political strategies.

Phase 3: Intelligence Synthesis & Strategic Action

  • Step 3.1: Identify the “Enforcement Gap”: If multiple entities are lobbying about a persistent market problem, and Catalan public records show no effective action, this constitutes a regional “Enforcement Gap”6666. This forms the basis of a complaint to the regional regulator or ombudsman (Síndic de Greuges).
  • Step 3.2: Frame a Regional USP: The intelligence gathered on an unresolved, heavily lobbied issue is the perfect foundation for a USP77. We can approach the relevant department of the Generalitat de Catalunya with a pre-packaged solution, using their own lobby register data as proof of the need.
  • Step 3.3: Inform Legal Challenges: The register provides crucial context for legal action. For instance, if a company wins a public contract after lobbying heavily for tender specifications that only it could meet, this data can be used to support a legal challenge to the tender award on grounds of bias.

Part III: Application to COCOO Doctrines

This model is designed to execute our core strategies within the Catalan jurisdiction.

Mind Map Doctrine Application of the Catalan Register Model
PTW (Political Time Window) By monitoring the register, we can identify emerging regional policy debates before they become public knowledge, allowing us to prepare our interventions to coincide with the Catalan parliamentary calendar for maximum effect8.
Challenge Discrpower The register provides evidence of who is attempting to influence regional public bodies. This data can be used to challenge a discretionary decision (e.g., granting an environmental permit) by questioning the impartiality of the process9999.
USP (Unsolicited Proposal) The “Thematic Monitoring” protocol (Step 2.2) is a direct mechanism for identifying regional problems. This allows us to craft a highly targeted USP to the Catalan government, positioning COCOO as a proactive problem-solver10101010.
Noisefilter A news report about a new Catalan policy is just noise. By using the register to see which corporations lobbied for that exact policy, we filter the noise and understand the true commercial interests behind the law11111111.
Competitor Analysis The register allows us to benchmark the political influence activities and priorities of our adversaries within Catalonia, revealing their strategic goals and vulnerabilities at a regional level12.
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www.cnmc.es

                                                                   


The COCOO CaseLink Doctrine: Standard Model for the CNMC Interest Group Register

Full URL: https://www.cnmc.es/ambitos-de-actuacion/registro-de-grupos-de-interes

Strategic Imperative

The CNMC’s lobby register is our primary tool for mapping the influence landscape in Spain concerning competition, market regulation, and state aid. It provides a direct line of sight into which companies and associations are actively trying to shape the policies that govern our target markets. This intelligence is fundamental to our pre-emptive and proactive doctrines.

This platform is mission-critical for:

  • Anticipating Regulatory Change: By seeing who is lobbying on what issues, we can predict future changes to competition law or sector-specific regulation, allowing us to prepare challenges or USPs in advance.
  • Informing “Challenge Discrpower” Strategy: If we are challenging a discretionary decision by the CNMC, knowing which parties have had extensive lobbying meetings with the regulator on that very topic provides context and potential lines of argument regarding undue influence.
  • Executing the “PTW (Political Time Window)” Doctrine: Lobbying activity often precedes a formal public consultation or legislative proposal. Identifying this activity gives us an early warning, allowing us to prepare our own counter-arguments and launch them at the moment of maximum political sensitivity.
  • Competitor Analysis: Understanding an adversary’s lobbying objectives reveals their strategic priorities, weaknesses, and the regulatory outcomes they fear most.

Part I: The Search Platform’s Rules & Functionality

The platform is a structured database with a straightforward, yet effective, search interface.

  • No Complex Operators: The search does not use advanced Boolean operators (AND, OR, NOT). It functions as a simple keyword and filter-based system.
  • Primary Search Fields:
    • Identificación (Identification): Search by the name of the interest group or company.
    • NIF: Search by the entity’s Spanish tax identification number for a precise match.
  • Filtering Capabilities: The real power lies in the filters that can be applied to see the activities of the lobbyists. For any registered entity, you can view a list of all their declared lobbying activities, which includes:
    • Actividades desarrolladas (Activities undertaken): A description of the specific lobbying action.
    • Materias tratadas (Subjects discussed): The policy area being discussed.
    • Periodo (Period): The time frame of the activity.
    • Personas con las que se han reunido (Persons with whom they have met): Critically, this can list the specific CNMC departments or officials they have met with.

Part II: The COCOO Strategic Search Model for the CNMC Register

This protocol provides the workflow for turning lobbying data into strategic intelligence.

Phase 1: Sectoral and Adversary Monitoring

  • Step 1.1: Identify Key Lobbyists: Create a list of the major companies and, just as importantly, the key trade associations (asociaciones) in our target sectors. Trade associations often lobby on behalf of an entire industry, revealing the sector’s collective strategic goals.
  • Step 1.2: Proactive Search & Alerts: On a monthly basis, run searches for each entity on our watchlist. The goal is to build a timeline of their lobbying efforts. Who are they meeting with? What subjects are they consistently raising?

Phase 2: The “Policy Shift” Analysis Protocol

This protocol is used to predict and pre-empt changes in regulation.

  • Step 2.1: Keyword-Based Subject Search: While you cannot search the entire database for a keyword, you can review the filings of key players for recurring themes. Look for subjects like modificación normativa (regulatory modification), ayudas públicas (state aid), concentraciones (mergers), or specific legislative file numbers.
  • Step 2.2: Identify Consensus or Conflict: Analyze the lobbying records of multiple major players in a single sector. Are they all lobbying for the same regulatory change? This indicates a powerful, unified industry push. Conversely, are they lobbying for opposing outcomes? This signals a market in conflict and creates a potential opening for COCOO to act as a mediator.
  • Step 2.3: Map the Influence Network: Pay close attention to the Personas con las que se han reunido field. Are all the major players meeting with the same Director-General at the CNMC? This identifies the key decision-maker within the regulator who is the focal point for industry pressure.

Phase 3: Intelligence Synthesis & Strategic Action

  • Step 3.1: Develop a Counter-Narrative: If our analysis shows a dominant player is lobbying to weaken consumer protection rules, we can use this intelligence to proactively prepare a data-driven counter-submission. We can align with consumer groups, citing the company’s own lobbying activity as evidence of their anti-competitive intent.
  • Step 3.2: Craft a Pre-emptive USP: If we see multiple players lobbying about a clear market inefficiency that the regulator is struggling to solve, this is a direct trigger for an Unsolicited Proposal (USP). Our USP will offer a solution (e.g., a new code of conduct, a technology-based monitoring platform) that solves the regulator’s problem and positions COCOO to be paid to implement it.

Part III: Application to COCOO Doctrines

This model is designed to feed directly into our core strategic frameworks.

Mind Map Doctrine Application of the CNMC Register Model
PTW (Political Time Window) The register provides the earliest possible indicator of an emerging policy debate. By tracking lobbying activity, we can anticipate when a “Political Time Window” will open (e.g., when the CNMC launches a formal consultation) and have our arguments ready to deploy immediately.
Challenge Discrpower If the CNMC makes a decision that benefits a company that has been intensely lobbying it, we can use the lobbying records as evidence to question the regulator’s independence and to add weight to a request for a formal review of the decision.
Noisefilter The entire register acts as a “Noisefilter”. Instead of reacting to public news, we are monitoring the private intentions of powerful companies, allowing us to distinguish between market noise and genuine strategic moves.
Lobby Tools This platform is the primary “Lobby Tool” for intelligence gathering. It tells us who our adversaries are, what they want, and who they are talking to, allowing us to craft a precise and effective counter-lobbying or public affairs campaign.
Benchmarking By analyzing the lobbying budgets and frequency of meetings of our competitors or adversaries, we can benchmark their level of investment in political influence, giving us a clearer picture of their commitment to a specific regulatory outcome.
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www.cnmv.es

                                                                   

The COCOO CaseLink Doctrine: Standard Model for the CNMV Portal

Full URL: https://www.cnmv.es/portal/consultas/BusquedaAvanzada.aspx

Strategic Imperative

The CNMV portal is our primary tool for monitoring the real-time behaviour of Spanish public limited companies (Sociedades Anónimas). It provides the official, regulated information necessary to track ownership changes, director dealings, and M&A activity. It is therefore mission-critical for:

  • MATOIPO (Merger, Acquisition, Takeover…) Analysis: The portal is the first place to find official announcements and filings related to any public M&A deal involving a Spanish-listed entity. 111
  • Uncovering “Stealth Consolidation”: By monitoring significant shareholding disclosures, we can track the “creeping control” of an acquirer or activist investor building a stake in a target company before a formal takeover bid is announced. 2
  • “TOP FCA Review” Equivalent: This portal allows us to perform the Spanish equivalent of a UK Financial Conduct Authority (FCA) review. We can scrutinize “pre-bid stakebuilding” and director’s dealings to ensure market rules are being followed. 333
  • RNS OC OS Strategy: The information gathered here is the “RNS” (Regulatory News Service) component for our Spanish targets. It provides the trigger events that we then investigate further using OpenCorporates (OC) and OpenSanctions (OS). 4444

Part I: The Search Platform’s Rules & Functionality

The Búsqueda Avanzada (Advanced Search) page is a powerful, filter-based tool. Mastering its specific fields is essential.

  • Entidad (Entity): Search for a specific company name.
  • Tipo de Información (Information Type): This is the most critical filter. It allows us to target specific types of regulated disclosures. For our purposes, the most important are:
    • Participaciones significativas (Significant shareholdings): Notifications of stakes that cross certain thresholds (typically 3%, 5%, 10%, etc.). This is key to tracking stakebuilding.
    • Autocartera (Treasury Stock): Information on a company’s own share buybacks.
    • Operaciones de consejeros y directivos (Transactions of directors and executives): The Spanish equivalent of “Director’s Dealings.”
    • Folletos de OPA (Takeover Bid Prospectuses): The official documents for a formal takeover offer.
    • Anuncios de OPA (Takeover Bid Announcements): The initial announcements of a takeover.
    • Información Privilegiada (Inside Information): Previously known as “Hechos Relevantes” (Material Facts), this is a catch-all for any price-sensitive information, including merger agreements.
  • Búsqueda por texto (Text Search): A keyword search that can be used within the “Información Privilegiada” category to find specific terms (e.g., fusión for merger, acuerdo for agreement).
  • Fechas (Dates): A crucial filter to narrow the search to a specific time window, allowing us to correlate market activity with other events.

Part II: The COCOO Strategic Search Model for the CNMV

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

Phase 1: Proactive Monitoring & Reactive Search

  • Step 1.1: Establish Sectoral Watchlist: Maintain a list of all CNMV-listed companies within our core target sectors. Run weekly checks on this list for any new filings, particularly “Participaciones significativas” and “Información Privilegiada”.
  • Step 1.2: Trigger-Based Investigation: When an external event occurs (e.g., news report, a “Noisefilter” alert), immediately initiate a targeted search on the relevant company.

Phase 2: The “Stakebuilding” Analysis Protocol

This protocol is used to detect potential “Stealth Consolid” or pre-bid activity.

  • Step 2.1: Initial Screen: Search the target company’s name. Set the Tipo de Información filter to Participaciones significativas. Set the date range for the last 6-12 months.
  • Step 2.2: Identify the Acquirer: Analyze the results to identify if a single entity is consistently increasing its stake. Note the name of this potential acquirer.
  • Step 2.3: Look for Concert Parties: Conduct new searches for “Participaciones significativas” in the same target company, looking for smaller stakes being acquired by different but potentially related entities. Cross-reference the names of these smaller acquirers with our other intelligence tools (OpenCorporates, InfoCIF) to see if they share directors or a common parent/BO with the main acquirer.
  • Step 2.4: Monitor Director Activity: Run a parallel search with the filter set to Operaciones de consejeros y directivos. Are the target company’s directors selling their shares immediately before a new stakebuilding announcement? This can be an indicator of coordinated activity.

Phase 3: The MATOIPO Protocol

This protocol is activated once a formal merger or takeover is announced.

  • Step 3.1: Retrieve Core Documents: Search the target company name. Set the Tipo de Información filter to Información Privilegiada and search for keywords like fusión (merger) or adquisición (acquisition) to find the initial agreement. Also, filter for Folletos de OPA to download the official offer document.
  • Step 3.2: Conduct Forensic Review: Scrutinize the offer document. It will contain crucial details about the offer’s conditions, the acquirer’s intentions, and financing. This is the primary source for building a legal challenge.
  • Step 3.3: Pre-Announcement Analysis: Go back and apply the “Stakebuilding” protocol (Phase 2) to the acquirer and target for the 12 months before the announcement. Did the acquirer build a significant undeclared stake through concert parties? Was there unusual director activity? This is evidence for a complaint to the CNMV regarding a breach of market rules.

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 CNMV Portal Model
Stealth Consolid 5 The “Stakebuilding” Analysis Protocol (Phase 2) is purpose-built to detect this. By aggregating multiple “Participaciones significativas” filings, we can prove a coordinated effort to gain control that circumvents the spirit of market regulations.
MATOIPO 666 The MATOIPO Protocol (Phase 3) provides the official documents and pre-deal intelligence necessary to analyze, and potentially challenge, any public takeover in Spain.
TOP FCA review / Pre-bid stakebuilding 7 The Pre-Announcement Analysis (Step 3.3) is our Spanish equivalent of this doctrine. It provides the evidence to challenge the legality and fairness of the process leading up to the bid.
RNS OC OS Filings on the CNMV (especially “Información Privilegiada” and “Participaciones significativas”) are the “RNS” trigger. They provide the names of entities and individuals that are then immediately researched on OpenCorporates (OC) and OpenSanctions (OS) to build a complete intelligence picture.
Noisefilter / Simple Indicators An announcement on the CNMV is raw data. Our analysis filters this “noise” by placing it in a strategic context. A sudden increase in treasury stock (“Autocartera”) could be a “Simple Indicator” that a company is trying to defend itself against a hostile bidder we have identified through our stakebuilding analysis.
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www.diputados.es

                                                                   

The COCOO CaseLink Doctrine: Standard Model for the Congreso de los Diputados Portal

Full URL: https://www.congreso.es/es/busqueda-de-diputados

Strategic Imperative

The Spanish Parliament’s member search portal is a primary intelligence source for understanding the political dimension of our cases. The individuals elected to this body shape legislation, scrutinize regulators, and influence public contracts. Investigating their declared interests and activities is fundamental to our “PTW (Political Time Window)” doctrine, allowing us to time our interventions for maximum political impact1. It also directly supports our “Challenge Discretionary Power” strategy by uncovering potential political motivations or conflicts behind regulatory and ministerial decisions2.

Our objective is to identify Members of Parliament (MPs) with declared financial interests, or those who are active on committees relevant to our cases, to anticipate legislative threats, identify political allies, and expose conflicts of interest that can be leveraged in a legal or commercial dispute.


Part I: The Search Platform’s Rules & Functionality

The portal is a structured database with specific search capabilities. It is not a full-text search engine, but a tool for precise filtering and profile access.

  • Primary Search Field (Nombre y/o apellidos): Allows searching for an MP by their first name or surname.
  • Legislature Filter (Legislatura): This is a critical filter that allows you to search for MPs from the current legislature or past ones. This is essential for historical analysis of a long-serving politician’s interests.
  • Parliamentary Group Filter (Grupo Parlamentario): Filters by political party or parliamentary group (e.g., Partido Popular, Grupo Socialista).
  • Constituency Filter (Circunscripción): Filters by the specific electoral district the MP represents.
  • Access to Declarations: The most important information is not on the search results page itself. You must click on an individual MP’s name to access their profile (Ficha de diputado). On this profile page, you will find links to their official declarations (Declaración de bienes y rentas and Declaración de actividades). These are static PDF documents.

Part II: The COCOO Strategic Forensic Protocol

This protocol details the systematic process for extracting actionable intelligence from the portal.

Phase 1: Proactive & Reactive Targeting

Our approach must be twofold:

  • Case-Specific Targeting (Reactive): When a case involves a specific industry (e.g., energy, banking) or geographic region, we must identify the MPs who are most influential in that domain.
  • General Monitoring (Proactive): We will maintain a database of MPs who sit on key committees (e.g., Economy, Industry, Health) and those with declared interests in our core sectors of operation.

Phase 2: The Search and Intelligence Gathering Protocol

  • Step 2.1: Identify Relevant Committees: Go to the “Comisiones” (Committees) section of the Congreso website. Identify the committees relevant to your case and extract the list of all member MPs.
  • Step 2.2: Search and Profile Individual MPs: Using the search tool, systematically search for each MP identified in Step 2.1. Access their individual profile page (Ficha de diputado).
  • Step 2.3: Download and Analyze Declarations: On the MP’s profile, download both their “Declaration of Assets and Income” (Declaración de bienes y rentas) and “Declaration of Activities” (Declaración de actividades). The latter often lists paid work or board positions held before becoming an MP, which can be a source of past conflicts.
  • Step 2.4: Forensic Document Review: Manually review these PDF documents. Search (using Ctrl+F or Cmd+F) for the names of companies involved in your case, their parent companies, major competitors, or relevant industry keywords. The goal is to find any declared financial link, no matter how small.

Phase 3: Synthesize and Weaponize the Intelligence

  • Step 3.1: Map the Conflict/Interest: If an MP who sits on the Health Committee has a declared shareholding in a pharmaceutical company bidding for a public health contract, this is a significant conflict of interest.
  • Step 3.2: Analyze Parliamentary Activity: On the MP’s profile page, review their recent “Iniciativas” (initiatives/questions) and “Intervenciones en Pleno” (speeches). Have they been asking parliamentary questions or speaking in a way that directly benefits their declared financial interests? This creates a pattern of behaviour.
  • Step 3.3: Link to Broader Strategy: This intelligence is rarely used in isolation. It is combined with our other findings. For example, linking an MP’s conflict of interest to a flawed public tender process (identified via procurement portals) creates a powerful narrative for a formal challenge.

Part III: Application to COCOO Doctrines

This protocol is purpose-built to execute key strategies from our mind maps.

Mind Map Doctrine Application of the Congreso Portal Protocol
PTW (Political Time Window) 3 By monitoring the parliamentary calendar and the activities of key MPs (Step 3.2), we can time the release of our findings or the filing of a complaint to coincide with a relevant parliamentary debate or committee hearing, ensuring maximum political pressure.
Challenge Discrpower / JR2COURT 4 If a Minister (who is also an MP) makes a discretionary decision, evidence of a conflict of interest from their parliamentary declaration can be submitted as part of a judicial review application, arguing the decision was biased or procedurally improper.
FOC DAM (Find Other Claimants) 5 If an MP with influence over a sector has a conflict of interest, it suggests a systemic issue. This can lead us to investigate whether other companies have been similarly disadvantaged, potentially uncovering new claimants for a group action.
Noisefilter 6 Information about a new policy or law is just noise. By identifying which specific MPs are pushing the policy and analyzing their financial interests, we can filter the noise and understand the true corporate interests driving the legislative agenda.
Lobby Tools The information gathered here is a direct input for our lobbying strategy. Identifying MPs who are knowledgeable about our sector but have no conflicts of interest makes them potential allies to approach. Conversely, identifying those with clear conflicts tells us who our primary political adversaries are.
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www.hacienda.COIS

                                                                   

The COCOO CaseLink Doctrine: Standard Model for the OCI Portal

Full URL: https://www.hacienda.gob.es/es-ES/SecretariaDeEstadoDeFuncionPublica/OficinaConflictoIntereses/Paginas/DeclaracionesdealtoscargosdelaAGE.aspx

Strategic Imperative

This portal, run by the Office of Conflict of Interests (OCI), is a critical resource for executing our “Challenge Discretionary Power” and “JR2COURT” (Judicial Review to Court) strategies. Its purpose is not to find companies, but to investigate the key public officials who make decisions that affect our cases—the ministers, secretaries of state, and heads of regulatory bodies.

The evidence found here provides leverage. A public official with an undeclared or problematic financial interest in a company or sector is compromised. We can use this information to:

  • Challenge a public tender award where the decision-maker had a potential conflict.
  • Question a regulator’s decision not to investigate a market (an “Enforcement Gap”), suggesting their impartiality is affected. 11111111111
  • Add significant weight to a judicial review application, arguing that a decision was tainted by improper interests. 2222222

Part I: The Search Platform’s Rules & Functionality

This platform is not a conventional search engine with advanced operators. It is a public archive. Understanding its structure is key to using it effectively.

  • No Dynamic Search Bar: There is no sitewide search function or advanced search form. You cannot search for keywords, company names, or asset types across all declarations simultaneously.
  • Document-Based Architecture: The portal is organised chronologically by the date of an official’s appointment or cessation. The declarations are published as static PDF or HTML files linked next to the official’s name and title.
  • Manual Investigation is Required: Accessing the information requires identifying the target individual first and then locating their specific declaration documents within the chronological lists. The “search” is therefore a manual, forensic process of document review.
  • Information Available in Declarations: Each declaration typically includes:
    • Real estate assets.
    • Bank deposits and financial assets (shares, investment funds).
    • Vehicles and other valuable assets.
    • Liabilities (loans, mortgages).

Part II: The COCOO Strategic Forensic Protocol

This is the standard model for extracting actionable intelligence from the OCI portal.

Phase 1: Target Identification (External)

The work begins before visiting the OCI portal.

  • Step 1.1: Identify the Decision-Maker: In any case involving a public body (e.g., a ministry, a regulator like the CNMC), identify the key senior official responsible for the decision in question. This could be the Minister, the Secretary of State, or the President of the regulatory agency.
  • Step 1.2: Determine their Term of Office: Note the dates when this individual was appointed and when they left office. This is crucial for locating the correct documents on the OCI portal.

Phase 2: Document Retrieval and Analysis

  • Step 2.1: Locate the Declaration: Navigate the OCI portal. The declarations are typically organised by government term (e.g., “XIV Legislatura”). Find the section corresponding to your target’s term of office.
  • Step 2.2: Download All Relevant Files: Locate your target official in the list. Download both their initial declaration (made upon taking office) and their final declaration (made upon leaving office). The comparison between the two is often where the most valuable intelligence lies.
  • Step 2.3: Forensic Document Review: This is the most critical step. Open the PDF files and manually search (using Ctrl+F or Cmd+F) for keywords relevant to your case. This includes:
    • The names of key companies in the sector.
    • The names of major investment funds known to be active in the sector. 333
    • Keywords for asset types (e.g., the Spanish word for shares, acciones).

Phase 3: Intelligence Synthesis and Leverage

  • Step 3.1: Identify the Conflict: The goal is to find a direct or indirect financial link between the official’s declared assets and the matter we are investigating. For example, does the Minister for Ecological Transition hold a significant stake in a fund that heavily invests in a company that just won a major energy contract?
  • Step 3.2: Compare Initial vs. Final Declarations: Analyse the change in the official’s wealth during their time in office. Was there a significant, unexplained increase in assets, particularly in funds or shares related to their portfolio?
  • Step 3.3: Cross-Reference with Other Intelligence: Correlate the dates of significant asset purchases or sales in the declaration with key policy decisions or public contract awards.
  • Step 3.4: Weaponise the Findings: The discovery of a conflict is a high-impact piece of evidence. It is not used for a broad public attack, but as a precise instrument in a formal submission to a court, a supervising body, or an anti-corruption prosecutor, arguing that a public decision is voidable due to a breach of impartiality.

Part III: Application to COCOO Doctrines

This forensic protocol is purpose-built to execute our most sophisticated strategies.

Mind Map Doctrine Application of the OCI Portal Protocol
Challenge Discrpower / JR2COURT This is the primary application. Finding a conflict of interest is the “silver bullet” in a judicial review. It shifts the argument from a disagreement on policy to a question of procedural illegality and the integrity of the decision-maker, which courts take extremely seriously. 4444444
CLP+WPI (Competition Law + Public Interest) When challenging a merger or a state aid decision, demonstrating that the approving official had a personal financial interest aligns our commercial objectives with the public interest in clean governance, making our complaint politically potent.
USP (Unsolicited Proposal) If we discover through our “Noisefilter” process that a public contract was awarded to a company linked to a decision-maker, we can use this evidence to challenge the award. The desired outcome is the cancellation of the tender, creating an opportunity for COCOO to propose a new, transparent process that we can mediate or bid for. 5
PTW (Political Time Window) Evidence of a conflict of interest has maximum impact when revealed during a sensitive political period, such as before an election or during a parliamentary hearing on the relevant department’s budget. The protocol requires timing the deployment of this intelligence for maximum effect. 6666
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www.INFOCIF.ES

                                                                   

www.infocif.es

InfoCIF operates on a “freemium” model. Basic company searches and access to limited public data (like company name and registration number) are free. However, to access the detailed financial reports, director information, shareholder structures, and other in-depth data crucial for our work, a fee is required. This is typically done by purchasing individual reports or through a subscription plan for frequent users. The cost for a single, comprehensive “Financial Report” is a key investment for any serious investigation

The COCOO CaseLink Doctrine: Standard Model for InfoCIF

Strategic Imperative

InfoCIF is a primary intelligence tool for any investigation involving Spanish entities. Its value lies in providing granular detail that supplements our broader international tools. While OpenCorporates can identify a Spanish company’s existence, InfoCIF provides the detailed financial health, director linkages, and shareholder information necessary to qualify it as a target or understand its role in a larger market dynamic.

This platform is indispensable for:

  • Ground-Truthing “Stealth Consolid”: When we suspect a series of small acquisitions are linked, InfoCIF can provide the financial statements to assess the acquirer’s capacity and the director information to prove hidden connections1.
  • MATOIPO Analysis: For any merger or acquisition involving a Spanish entity, InfoCIF is our source for the detailed due diligence required to uncover risks or challenge the transaction’s premises22.
  • Identifying “Simple Indicators”: InfoCIF reports are rich with financial ratios and corporate data that serve as “Simple Indicators” of a company’s health, distress, or aggressive market posture3.

Part I: The Search Platform’s Rules (InfoCIF)

Mastery of the tool requires understanding its specific search architecture. InfoCIF’s power comes from its numerous, highly specific search fields.

  • Primary Search Identifiers: You can search by:

    • Nombre de empresa (Company Name): For searching a known entity.
    • CIF (Código de Identificación Fiscal): The unique tax identification number for a Spanish company. This is the most precise way to search, eliminating all ambiguity.
    • Nombre o NIF de directivo o administrador (Name or Tax ID of a director): This is a critical function for mapping networks.
  • Advanced Search Filters (Búsqueda Avanzada): The advanced search page is where we can execute highly targeted intelligence gathering. Key filters include:

    • Ubicación (Location): Filter by Province and Locality within Spain.
    • Actividad (Activity): Search by CNAE codes (the Spanish equivalent of SIC codes) or by activity keywords. This is essential for sector-wide analysis.
    • Datos Económicos (Economic Data): Filter companies by their sales volume (Ventas), number of employees (Número de empleados), or financial ratios. This allows us to isolate companies of a certain size or financial profile.
    • Forma Jurídica (Legal Form): Filter by entity type (e.g., S.L. – Limited Liability Company, S.A. – Public Limited Company).
    • Estado (Status): Filter for active (Activa) or inactive companies.
    • Cargos Directivos (Executive Positions): Search for companies where a specific person holds a directorship.

Part II: The COCOO Strategic Search Model for InfoCIF

This protocol ensures we extract maximum strategic value from InfoCIF in any given case.

Phase 1: Precision Targeting

  • Step 1.1: Use the CIF: Whenever possible, initiate searches using the company’s CIF, obtained from other documents or initial searches. This guarantees a precise match.
  • Step 1.2: Sectoral Sweep: To understand a specific market segment, use the “Advanced Search” to filter by the relevant CNAE code and the specific Province of interest. This produces a comprehensive list of all direct competitors in a defined geographic and industrial market, directly supporting our “Benchmarking” and “Competitor Analysis” strategies4.

Phase 2: The Network and Influence Protocol

  • Step 2.1: Director Search: The most powerful function for our purposes is the ability to search by a director’s name (Nombre de directivo). When analyzing a key company, identify all its directors from the InfoCIF report.
  • Step 2.2: Reverse-Engineer the Network: Systematically search the name of each of those directors to generate a list of all other Spanish companies where they currently hold or have held a position. This is a primary method for uncovering undeclared related-party transactions and mapping the true influence network of key individuals.

Phase 3: Financial & Distress Signal Analysis

  • Step 3.1: Acquire the Financial Report: For any high-priority target, purchase the full “Informe Financiero”.
  • Step 3.2: Look for Red Flags: Scrutinize the financial statements for “Simple Indicators” 5 of distress or unusual activity:
    • Rapidly increasing debt levels.
    • Plummeting profit margins.
    • Significant changes in shareholder structure.
    • Mentions of legal disputes or contingencies in the notes to the financial statements.
  • Step 3.3: Benchmark Against Peers: Compare the target company’s key financial ratios (e.g., liquidity, debt-to-equity) against the sectoral averages provided by InfoCIF or against the data from the list of competitors generated in Step 1.2. A significant negative deviation is a powerful indicator of weakness that can be exploited.

Part III: Application to COCOO Doctrines (Mind Map Integration)

This model is not for general research; it is a weapon to execute our specific strategic plays.

Mind Map Doctrine Application of the InfoCIF Model
Stealth Consolid & MATOIPO Use the Director Search (Step 2.2) to identify a common director across multiple acquiring companies in the same CNAE sector. This provides strong circumstantial evidence of a coordinated acquisition strategy that regulators may have missed666.
Noisefilter & Simple Indicators The Financial & Distress Signal Analysis (Phase 3) is our primary “Noisefilter”7. A company showing poor financial health via its InfoCIF report is a prime target for a challenge, as it may lack the resources to fight a sustained legal battle.
FOC DAM (Find Other Claimants) If a company is found to be engaged in harmful practices, using the Director Search to find sister companies controlled by the same management team allows us to immediately search for other groups of victims, expanding the scope of the case8.
Benchmarking / Porter The Sectoral Sweep (Step 1.2) provides the raw data needed to conduct a rigorous analysis of market structure, identifying the key players and their relative financial strengths as a precursor to any market intervention9.
Uncovering Undisclosed Mergers As identified in the research, many mergers are not publicly announced10. A sharp, unexplained increase in a company’s assets or a sudden disappearance of a competitor from the “active” list in a sectoral search on InfoCIF can be an indicator of an unannounced acquisition that requires further investigation.
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www.register.openownership.org/search

                                                                   


BOR REGISTER MAIN

The OpenOwnership Register is not merely a database; it is our primary tool for identifying the true “beneficial owner” (BO)—the specific human who ultimately owns, controls, or benefits from a corporate entity. 3 This is critical because, as our intelligence shows, anticompetitive actions are frequently hidden by layering companies across multiple jurisdictions, including secrecy jurisdictions. 4 While our other tools can identify companies, this register identifies the people behind them.

Our application of this tool is therefore central to our core strategies:

  • Uncovering Stealth Consolidation: By mapping the ownership of multiple, seemingly independent companies back to a single BO, we can prove that a market is far more concentrated than it appears. 
  • Informing MATOIPO Analysis: In any merger, acquisition, or takeover, identifying the ultimate BO of all parties is essential to understand the true strategic intent and to determine if a transaction triggers undisclosed competition issues. 
  • Executing FOC DAM: Discovering a single BO behind multiple companies engaged in harmful practices exponentially increases our ability to “Find Other Claimants” and “Monetise Damages,” creating a much larger and more valuable case. 

Part I: The Search Platform’s Rules (OpenOwnership Register)

To excel at our mission, we must first master the tool’s capabilities. The OpenOwnership Register’s search functionality is based on the following principles.

  • Universal Search Bar: The primary search box queries across all indexed data, including person names, entity names, and identifiers.
  • Entity Types: The register differentiates between three main types of records you will encounter in a search:
    • Beneficial Owner: An individual (a real person). This is our primary target.
    • Entity: A legal entity like a limited company or a partnership.
    • Interested Party: An entity that has an interest in the subject company but is not a direct beneficial owner (e.g., another company in the ownership chain, a state-owned entity with control rights).
  • Filtering Capabilities: The most powerful features are the filters available after an initial search is performed. These are the key to refining our intelligence. The main filters are:
    • Record type: Allows you to view only “Beneficial owners,” “Entities,” or “Interested parties.”
    • Jurisdiction: Narrows results to entities registered in a specific legal jurisdiction (e.g., United Kingdom, Nigeria).
    • Country: Filters individuals or entities by their stated country. This is useful for tracking the global footprint of a specific BO.
  • Search Syntax: The register uses a straightforward search system and does not publicly detail complex Boolean operators (like AND, OR, NOT) or proximity searches. The intended methodology is to perform a broad name search and then use the rich filtering options to narrow the results. For precision, searching for exact names in quotation marks (e.g., "Johnathan Doe") is standard best practice.

Part II: The COCOO Strategic Search Model

This is the standard protocol for any investigation using the OpenOwnership Register. It is designed to be systematic and to build a complete network map of ownership and control.

Phase 1: Target Identification (Pre-Search)

Never begin a search blind. Your starting point must be intelligence gathered from our other platforms (e.g., Companies House, LSE RNS, Violation Tracker).

  • Step 1.1: Compile Target List: From your initial investigation, create a list of key names. This must include:
    • The target company name(s).
    • The names of all current directors and Persons with Significant Control (PSCs) from Companies House.
    • The names of any parent companies or major corporate shareholders.

Phase 2: The Multi-Layered Search Protocol

  • Step 2.1: The Entity Search:

    • Search for the primary target company name.
    • On the results page, analyze the list of declared “Beneficial owners.” Record every name.
    • Note the “Jurisdiction” filter. Does the company have declarations in multiple countries? This is a red flag for a complex structure.
  • Step 2.2: The Person Search:

    • Systematically search for every individual director and PSC name from your target list compiled in Phase 1.
    • For each person, analyze the search results. Does their name appear as a BO for the target company? For other, unexpected companies? Record all associated entities.
  • Step 2.3: The Network Expansion (The Critical Step):

    • This step turns intelligence into a strategic map. Take the name of a key Beneficial Owner identified in Step 2.1 or 2.2.
    • Conduct a new search using only the BO’s name.
    • The result is a list of every single entity in the database for which this person is a declared beneficial owner. This is how we find the hidden connections and prove stealth consolidation.
  • Step 2.4: Jurisdictional Analysis:

    • During the Network Expansion search, use the “Jurisdiction” filter.
    • Filter the BO’s ownership network by secrecy jurisdictions (e.g., British Virgin Islands, Cayman Islands, etc.) to identify where financial assets and control may be deliberately obscured. 8888

Phase 3: Evidence Analysis & Integration

  • Step 3.1: Map the Ownership Structure: Use the collected data to draw a visual mind map of the ownership chain, connecting the ultimate BO to all intermediate and target-level entities.
  • Step 3.2: Aggregate Control: If a single BO owns, for example, 15% of three different “competitors” in a highly segmented market, their effective control over that market segment is far greater than any single holding suggests. This is the core evidence for a “Stealth Consolidation” complaint. 9
  • Step 3.3: Synthesize and Escalate: Integrate these findings with our other intelligence streams. Does a BO’s network of companies show up on Violation Tracker? Did an LSE RNS announcement about a “minority stake” acquisition coincide with a change in BO declaration? This synthesis forms the basis of a formal complaint to regulators or a USP. 

Part III: Application to COCOO Doctrines

This model directly operationalizes our core strategic principles from the mind maps:

Mind Map Doctrine Application of the OpenOwnership Register Model
Stealth Consolid 11 The Network Expansion Protocol (Step 2.3) is the exact mechanism to uncover this. It connects disparate companies through a common BO, providing prima facie evidence of consolidation that falls below M&A notification thresholds.
MATOIPO Analysis 12 Before acting on any M&A announcement, this model must be run on all acquiring and target entities to confirm the identity of the ultimate BOs. This verifies if the deal is a simple transaction or part of a larger, undeclared strategic consolidation.
FOC DAM 13 If we identify a harmful practice at one company, using this model to find other companies controlled by the same BO allows us to proactively find new classes of victims suffering from the same practices, dramatically increasing the scope of the potential claim.
JR2COURT / Challenge Regulators 14 When we file a complaint with a regulator (e.g., the CMA), submitting a detailed ownership map from this model as evidence makes our claim far more credible. It prevents the regulator from dismissing the issue as isolated and forces them to confront the systemic nature of the problem we have uncovered.
Noisefilter 15 An alert from another platform (e.g., an RNS announcement) is just noise. Running the involved parties through this BO model is the filter that qualifies the event as a genuine opportunity or a false alarm.
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www.uk.parlm.petitions

                                                                   

Solicitor’s Briefing: Live Opportunities on the UK Petitions Platform

Objective: To identify public policy areas where citizen engagement signals a clear failure of existing mechanisms, presenting an entry point for Cocoo’s mediation services or for an unsolicited project proposal.

Methodology: The 4-step model (Scope, Execute, Analyse, Leverage) was applied by querying the petitions database for recently debated, rejected, and technology-related petitions.

Executive Summary: Analysis of the petitions platform reveals two significant and immediate opportunities. The first is a mediation opportunity arising from a recurring theme of rejected petitions related to local-level disputes. The second is a clear opening for a public contract proposal, prompted by a specific government response to a petition concerning animal welfare data.


Opportunity A: Mediation Services for Local Planning & Development Disputes

  • Evidence: A systematic search for petitions rejected in 2025 reveals a distinct pattern: numerous petitions concerning local planning, development, and neighbour disputes are rejected with the standard reason: “This is about a local issue… We can only accept petitions about things the UK Government or Parliament are directly responsible for.” A recent example is a petition concerning escalating service charges by a new management company at a residential development in Wales, which was raised in the Senedd on 18 June 2025 but falls outside the UK Parliament’s direct remit.

  • Analysis (Opportunity Identification): This pattern represents a systemic failure. Citizens are attempting to use national tools to solve intractable local problems because they have exhausted local remedies or feel unheard. The official rejection explicitly confirms that these are disputes that need to be resolved at a local or private level, yet they are clearly not being resolved. This creates a vacuum for a neutral third party.

  • Leverage (Recommended Next Steps):

    1. Target Identification: We will compile a list of the 20 most-signed rejected petitions from the last 12 months related to “planning,” “development,” “service charges,” and “local council disputes.”
    2. Proposal for Mediation Services: Draft a templated proposal to the specific local councils mentioned in these petitions. The proposal will reference the petition number and signature count as hard evidence of resident dissatisfaction.
    3. Positioning: We will position Cocoo as a provider of “Community Dispute Resolution Services,” offering a structured, de-escalating alternative to costly legal battles and unresolved resident frustration. We can propose a low-cost initial consultation to demonstrate value.

Opportunity B: Public Contract for an Animal Welfare Data Hub

  • Evidence: The petition “End the use of cages and crates for all farmed animals” (106,667 signatures) was debated in Parliament on 16 June 2025. The petition “Introduce Licensing and Regulation for Dog and Cat Rescues” received a government response on 6 June 2025. In both cases, the government’s response, while sympathetic, highlighted the complexity and lack of centralised data. For the rescue petition, the government stated it is “developing an overarching approach to animal welfare and will outline more detail in due course.” For the farming petition, the debate highlighted disparities in standards and data across the UK.

  • Analysis (Opportunity Identification): The government’s phrase “developing an overarching approach” is a clear signal for a policy in formation. A recurring theme in animal welfare debates is the need for better data to inform policy and ensure enforcement. There is a clear gap for a technology solution that can provide a unified data platform for welfare standards, licensing, and inspection reporting across various animal sectors.

  • Leverage (Recommended Next Steps):

    1. Develop Unsolicited Proposal: Draft a concept note for a low-value, fixed-cost project: “The UK Animal Welfare Data Hub: A Feasibility Study & Pilot.”
    2. Positioning: The proposal will directly address the government’s stated need for an “overarching approach.” It will position Cocoo not just as a technology provider, but as a strategic partner to DEFRA (Department for Environment, Food & Rural Affairs). The project would aim to create a single, transparent dashboard for tracking licensing and welfare standards, starting with a pilot for dog and cat rescues, leveraging the public interest from the recent petition.
    3. Submission: This proposal should be submitted to the relevant policy teams at DEFRA, referencing both petitions as evidence of urgent public and parliamentary interest in finding a tangible solution. This proactive step positions Cocoo to shape the eventual tender and establishes us as the leading expert in the field.
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