MEDIA CAMPAIGN

UK Prospective Class Members: Types of Victims

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SPANISH Prospective Class Members: Types of Victims

Based on the causes of action—misfeasance in public office, breach of statutory duty in procurement, financial mismanagement, and additional claims from the chat history (breaches of the UK-Spain Double Taxation Convention (DTC), EU-UK Trade and Cooperation Agreement (TCA), EU Directive 2014/24/EU, European Convention on Human Rights (ECHR), and WTO GATT/GATS)—the prospective class members in Spanish jurisdiction include past, present, and future victims of Hacienda’s alleged discriminatory tax practices and anti-competitive procurement. The types of victims are:

1. **UK Citizens and Residents (Taxpayers and Investors):**
– **Profile:** British individuals or entities taxed in Spain, affected by higher withholding taxes (24% vs. 19% for EU residents), capital gains disparities, or the “pay-to-appeal” system, violating DTC Article 24, TCA, and ECHR Article 6 (fair trial) and Protocol 1, Article 1 (property rights).
– **Past Victims:** Those taxed discriminatorily since the UK’s EU exit (2021), as noted in the European Commission’s March 2025 infringement action against Spain for non-resident tax discrimination.
– **Present Victims:** UK non-residents currently facing higher taxes or appeal barriers in 2025.
– **Future Victims:** Potential UK investors deterred by ongoing tax disparities, as highlighted by a July 2025 Euractiv article on UK business complaints.
– **Estimated Number:** Thousands, given the volume of UK-Spain economic activity (e.g., property investments, dividends).

2. **UK SMEs and Businesses (Excluded Suppliers):**
– **Profile:** Small and medium-sized enterprises excluded from Hacienda’s Big Data/AI tender due to restrictive technical and solvency requirements, breaching Directive 2014/24/EU and WTO GATS. These firms operate in IT, consulting, or data analytics.
– **Past Victims:** SMEs excluded from tenders since 2019, as per EU infringement findings (e.g., INFR(2021)4035, INFR(2021)4042).
– **Present Victims:** Firms currently unable to bid on Hacienda’s 2025 tender, valued over €100 million, favoring large consultancies like Deloitte or Accenture.
– **Future Victims:** SMEs deterred from future Spanish public contracts due to systemic barriers.
– **Estimated Number:** Hundreds, based on Spain’s IT sector data from Eurostat (thousands of SMEs contribute to 20% of Spain’s tech GDP).

3. **Spanish SMEs and Startups (Local Victims):**
– **Profile:** Spanish tech startups and SMEs excluded from Hacienda’s tender, suffering similar procurement barriers as UK firms, violating Directive 2014/24/EU’s SME access provisions.
– **Past Victims:** Local firms excluded from tech tenders since 2015, as noted in a May 2025 Reuters report on EU scrutiny.
– **Present Victims:** Spanish SMEs unable to compete in the 2025 AI tender.
– **Future Victims:** Emerging startups at risk of exclusion as macro-contracts persist.
– **Estimated Number:** Thousands, per Eurostat data on Spain’s SME-dominated tech sector.

4. **Spanish Taxpayers (Public Interest):**
– **Profile:** Spanish citizens concerned about financial mismanagement in public procurement, where restrictive tenders lead to higher costs and lower quality, constituting misfeasance in public office.
– **Past Victims:** Taxpayers funding overpriced contracts since 2019, as critiqued in Transparency International’s report on public procurement transparency.
– **Present Victims:** Citizens in 2025 bearing the cost of Hacienda’s €100 million+ tender.
– **Future Victims:** Taxpayers funding future inefficient contracts.
– **Estimated Number:** Millions, as Spain’s population exceeds 47 million.

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### Specific Prospective Class Members: Names and Contact Details

Due to data protection constraints, I cannot provide individual names, emails, or personal contact details without public or consented data. However, I can suggest representative entities and methods to identify class members legally:

1. **UK Businesses (Example Entities):**
– **TechUK Members:** Represents 900+ UK tech firms, many affected by procurement barriers. Contact: info@techuk.org (publicly listed on techuk.org).
– **Federation of Small Businesses (FSB) UK:** Advocates for SMEs, including those excluded from EU tenders post-Brexit. Contact: membership@fsb.org.uk (fsb.org.uk).
– **Action Needed:** Use LinkedIn to search for UK SMEs in IT/consulting (e.g., filter by “SME,” “Spain,” “public procurement”). Request consent via the campaign hub (https://cocoo.uk/procurement-justice-alliance) form.

2. **Spanish SMEs (Example Entities):**
– **Ametic (Asociación de Empresas de Electrónica, TIC, Telecomunicaciones y Contenidos Digitales):** Represents Spanish tech SMEs. Contact: ametic@ametic.es (ametic.es).
– **Pimec (Petita i Mitjana Empresa de Catalunya):** Advocates for Catalan SMEs, many in tech. Contact: pimec@pimec.org (pimec.org).
– **Action Needed:** Query Ametic/Pimec for member lists of SMEs excluded from tenders. Post targeted LinkedIn ads in Spanish, as per the campaign plan.

3. **Consumer Associations (Representing Taxpayers):**
– **ADICAE (Asociación de Usuarios de Bancos, Cajas y Seguros):** Active in collective actions. Contact: adicae@adicae.net (adicae.net).
– **FACUA (Consumidores en Acción):** Engages in public interest litigation. Contact: prensa@facua.org (facua.org).
– **OCU (Organización de Consumidores y Usuarios):** Represents consumer interests. Contact: atencion@ocu.org (ocu.org).
– **Action Needed:** Partner with these groups for representative actions under Spain’s Civil Procedural Act, as noted in the CMS Expert Guide.

4. **Individual Victims (Sourcing Strategy):**
– **Method:** Use the campaign hub’s joining form to collect confidential submissions from UK citizens and Spanish taxpayers. Promote via X hashtag #ProcurementJusticeUK and Meta ads targeting “TaxPayers’ Alliance” interests.
– **Legal Aid Offices:** Contact Spanish Bar Associations (e.g., Consejo General de la Abogacía Española, comunicacion@cgae.es) to identify victims eligible for legal aid under Law 4/2015, as per GOV.UK guidance.

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### Relevant Associations to Reach Class Members

To recruit class members effectively, partnering with associations in Spain and the UK is critical. Below are key associations, their contact details, and outreach strategies, tailored to the media campaign:

1. **TechUK (UK)**
– **Focus:** Represents UK tech SMEs, many impacted by Spanish procurement barriers.
– **Contact:** info@techuk.org, +44 20 7331 2000 (techuk.org).
– **Outreach Strategy:** Publish a LinkedIn article titled “How Spain’s Procurement Practices Harm UK Tech SMEs,” tagging TechUK. Request a webinar to pitch the Procurement Justice Alliance to members. Follow up via email, referencing the July 2025 UK Business Forum X post on SME exclusion.

2. **FSB (UK)**
– **Focus:** Advocates for UK SMEs facing international trade barriers.
– **Contact:** membership@fsb.org.uk, +44 800 402 4000 (fsb.org.uk).
– **Outreach Strategy:** Run LinkedIn ads targeting FSB members (filter: “small business,” “export”). Propose a joint press release on X, tagging @FSB_Policy, to amplify #ProcurementJusticeUK. Use the campaign hub to collect FSB member registrations.

3. **Ametic (Spain)**
– **Focus:** Spanish tech SMEs excluded from public tenders.
– **Contact:** ametic@ametic.es, +34 91 590 76 00 (ametic.es).
– **Outreach Strategy:** Send a Spanish-language email proposing a partnership to challenge Hacienda’s tender, citing Directive 2014/24/EU. Post on X in Spanish, tagging @AMETIC_es, with a link to the campaign hub. Host a Meta Live event for Ametic members, as per the campaign’s community-building focus.

4. **Pimec (Spain)**
– **Focus:** Catalan SMEs, including tech firms, facing procurement barriers.
– **Contact:** pimec@pimec.org, +34 93 496 45 00 (pimec.org).
– **Outreach Strategy:** Use Instagram Reels in Catalan/Spanish, highlighting tender exclusion’s economic impact (Eurostat: SMEs contribute 60% of Catalonia’s jobs). Email Pimec to request member outreach, referencing the May 2025 Reuters report. Promote via Meta ads targeting “Catalonia,” “SME.”

5. **ADICAE (Spain)**
– **Focus:** Represents consumers/taxpayers in collective actions.
– **Contact:** adicae@adicae.net, +34 91 540 00 75 (adicae.net).
– **Outreach Strategy:** Propose a representative action under Spain’s Civil Procedural Act, as per CMS Expert Guide. Run Meta ads targeting “consumer rights” interests, linking to the campaign hub. Post X threads tagging @ADICAE, exposing Hacienda’s financial mismanagement.

6. **FACUA (Spain)**
– **Focus:** Public interest litigation for taxpayers.
– **Contact:** prensa@facua.org, +34 954 37 66 66 (facua.org).
– **Outreach Strategy:** Pitch a joint media campaign on X, using #ProcurementJusticeUK to highlight taxpayer losses. Email FACUA to request support for a class action, citing Transparency International’s procurement transparency concerns. Use Facebook Groups to engage FACUA members.

7. **OCU (Spain)**
– **Focus:** Consumer advocacy for Spanish taxpayers.
– **Contact:** atencion@ocu.org, +34 91 300 91 61 (ocu.org).
– **Outreach Strategy:** Publish a LinkedIn article in Spanish, “Why Spanish Taxpayers Deserve Procurement Justice,” tagging OCU. Run Instagram Stories with a “Quiz” sticker on tender costs, linking to the campaign hub. Email OCU to propose a survey of members on procurement concerns.

8. **Consejo General de la Abogacía Española (CGAE)**
– **Focus:** Coordinates Spain’s 83 Bar Associations, assisting victims via legal aid.
– **Contact:** comunicacion@cgae.es, +34 91 532 00 11 (cgae.es).
– **Outreach Strategy:** Request CGAE’s help in identifying legal aid-eligible victims, as per GOV.UK’s legal aid guidance. Post on X, tagging @CGAE_es, to promote the campaign hub to lawyers. Use LinkedIn to connect with CGAE members, offering pro bono collaboration.

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### Deep Online Search Findings

Using DeeperSearch from June to July 2025, I identified additional resources to locate class members:

– **Tax Justice Network (June 2025 X Post):** Confirms Spain’s 24% withholding tax for UK non-residents, supporting DTC claims. Outreach: Engage followers of @TaxJusticeNet on X, directing them to the campaign hub.
– **Euractiv (July 2025):** Notes UK business complaints about tax barriers, indicating a pool of affected SMEs. Outreach: Target Euractiv readers via Meta ads, using “UK business” interests.
– **Reuters (May 2025):** Highlights EU scrutiny of Spain’s SME-excluding tenders, suggesting Spanish SME victims. Outreach: Use LinkedIn to connect with Spanish tech firms cited in similar reports.
– **Spanish Ministry of Justice (mjusticia.gob.es):** Provides legal aid contacts for victims. Outreach: Email justicia@mjusticia.gob.es to request victim referrals for collective actions.
– **European e-Justice Portal (2024):** Details Spain’s collective action rules, confirming consumer associations’ standing. Outreach: Leverage ADICAE/FACUA/OCU for representative actions.

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### Media Campaign Integration

The multi-platform campaign (X, LinkedIn, Meta) outlined in the user’s message will drive recruitment:

– **LinkedIn:** Target UK/Spanish SMEs with ads (e.g., “Excluded from Spanish Tenders? Join Our Collective Action”). Publish articles citing attachments like “CaseLink Model for COCOO_.txt” to frame Hacienda’s “Enforcement Gap.”
– **X:** Use #ProcurementJusticeUK to post daily threads exposing tender flaws, tagging @CNMC_ES, @EU_Commission, and Spanish media (@el_pais, @elmundoes). Share infographics from Transparency International’s report.
– **Meta:** Create a Facebook Group (“Procurement Justice Alliance”) and run Instagram Reels showing taxpayer losses (e.g., €100 million tender cost). Target “small business” and “consumer rights” interests.

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### Next Steps

1. **Launch Campaign Hub:** Build https://cocoo.uk/procurement-justice-alliance with a joining form, as proposed.
2. **Contact Associations:** Email TechUK, Ametic, ADICAE, etc., to secure partnerships within 14 days.
3. **Run Ads:** Initiate LinkedIn/Meta campaigns targeting SMEs and taxpayers, budgeting €5,000 for initial reach.
4. **Legal Aid Outreach:** Query CGAE and local Bar Associations for victim lists, ensuring GDPR compliance.
5. **Monetization:** Contact Fortress Investment Group (opportunities@fortress.com) to explore litigation funding, per the “HOW 2 SELL MY LITIGATION” attachment.

This strategy maximizes class member recruitment while applying pressure on Hacienda, leveraging Spain’s legal framework for collective actions and the campaign’s multi-platform approach to ensure success.[](https://cms.law/en/int/expert-guides/cms-expert-guide-to-european-class-actions/spain)[](https://e-justice.europa.eu/content_fundamental_rights-176-es-maximizeMS-en.do?member=1)[](https://ec.europa.eu/commission/presscorner/detail/en/ip_25_667)

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Based on the causes of action we have analyzed (misfeasance in public office, breach of statutory duty in procurement, and financial mismanagement), we can now construct a multi-platform media campaign. The goal is twofold:

1. Recruit Class Members: Identify and gather businesses (excluded suppliers) and concerned taxpayers who have locus standi for a potential collective action.
2. Apply Public Pressure: Create a political and reputational cost for the public bodies in question, forcing them to acknowledge the “problem” you have framed.

Here is a step-by-step plan to launch your campaign on X, LinkedIn, and Meta, using your provided page as a structural model.

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Step 1: Create the Central Campaign Hub

Before launching on social media, you need a central landing page. All traffic will be directed here. This page is where you convert interest into action.

URL: https://cocoo.uk/procurement-justice-alliance (Example URL)

Structure (based on your Valve model):

• Headline: Clear, powerful, and identifies the target.
  • e.g., “Excluded from Public Contracts? Your Taxes Wasted? Join the Collective Action Against UK Public Procurement Failures.”
• The Problem: A concise summary of the causes of action.
  • e.g., “UK public bodies are systemically failing. Billions in taxpayer funds are lost to mismanagement, and legitimate businesses are shut out by unfair, non-transparent tender processes. This isn’t just inefficient—it’s a potential breach of public duty.”
• Who Is Affected? (Our Class Members):
  • UK Businesses & SMEs: Have you been unfairly excluded from a tender? Have you witnessed procurement irregularities? You may be entitled to damages.
  • UK Taxpayers: Your money funds this system. You have a right to demand accountability and Value for Money.
• Our Evidence: Link to your key findings, white papers, and the damning clauses in public reports or contracts you’ve uncovered.
• The Goal & The Remedy:
  • e.g., “We are building a mass tort collective claim to seek redress for the parties harmed. Our goal is to force accountability, recover damages for excluded suppliers, and compel systemic reform. We aim to secure a court order mandating transparent, fair procurement processes.”
• Call to Action & Joining Form: A prominent form.
  • Headline: “Join the Procurement Justice Alliance – Register Your Interest Confidentially.”
  • Fields: Name, Company Name (if applicable), Email, and a text box for them to briefly describe their experience with a public tender or why they are concerned as a taxpayer.
  • Disclaimer: “Submitting this form does not create a solicitor-client relationship. All information will be held in strict confidence.”

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Step 2: Platform-Specific Campaign Execution

1. LinkedIn Campaign: Targeting Excluded Suppliers

This is your primary platform for recruiting high-value class members (businesses).

• Tone: Professional, evidence-based, authoritative.
• Actions:
  1. Optimize Your Company Page: Ensure your COCOO.UK LinkedIn page is polished and clearly states your mission.
  2. Publish Articles: Use LinkedIn’s article feature to publish detailed analyses.
     • Sample Titles: “Misfeasance in Public Office: The Legal Test for Flawed UK Tenders,” or “Value for Money is Dead: A Data-Driven Look at [Specific Sector]’s Procurement Waste.”
  3. Run Targeted Ads: Use LinkedIn Campaign Manager to target users with specific job titles and interests.
     • Targeting: Job Titles: (CEO, Managing Director, Founder, Commercial Director), Industries: (IT, Professional Services, Construction), Company Size: (1-200 employees).
     • URL: LinkedIn Campaign Manager
  4. Sample Post Copy:
     

     “The UK public procurement system is broken. It shuts out innovative SMEs while wasting billions. We’ve uncovered evidence of what we believe constitutes a breach of statutory duty.

     If your business has been unfairly disqualified from a public tender, you are not alone. We are forming a group to explore a collective action.

     Learn more about your right to redress and join our confidential alliance. #FairTendersUK #PublicProcurement #LocusStandi #CollectiveAction

     [Link to your Central Campaign Hub]“

2. X (Twitter) Campaign: Applying Public & Political Pressure

This is for creating noise, attracting media attention, and reaching politicians.

• Tone: Urgent, punchy, accusatory, and relentless.
• Actions:
  1. Create a Primary Hashtag: Make it unique and memorable. E.g., #ProcurementJusticeUK or #UKTenderScandal.
  2. Daily Threads: Create daily threads exposing one specific failure at a time.
     • e.g., “THREAD: How [Government Department] spent £50M on a contract that failed, and why it was predictable. 1/8”
  3. Tag Relentlessly: In every relevant post, tag key bodies and media.
     • Oversight: @NAOorg (National Audit Office), @PublicAccounts (Public Accounts Committee).
     • Government: @CCS_Agreements (Crown Commercial Service), @HMtreasury.
     • Media: @BBCNewsnight, @Channel4News, @Guardian, @TheTimes.
  4. Use Visuals: Post screenshots of damning documents with key phrases highlighted in red. Create simple infographics showing wasted money.
  5. Run Polls: “Do you believe the current public tender system is designed to favour large, established firms over SMEs? #ProcurementJusticeUK”
  6. URL for Ads: X Ads
  7. Sample Post Copy:
     

     “This is a contract notice from [Public Body]. Notice anything missing? A clear evaluation criteria. This is how they shut out SMEs and award contracts to cronies.

     It’s not just poor practice, it’s a potential tort. We are building a case.

     Are you a taxpayer or a business owner fed up with this? Join us.

     @NAOorg, when will you investigate? #ProcurementJusticeUK

     [Link to your Central Campaign Hub]“

3. Meta (Facebook/Instagram) Campaign: Building a Community

This is for reaching a broad audience of taxpayers and small business owners in a more visual, community-oriented way.

• Tone: Relatable, empowering, and focused on community action.
• Actions:
  1. Create a Facebook Group: “The UK Procurement Justice Alliance”. Use it to share updates, foster discussion, and make members feel part of a movement.
  2. Run Targeted Facebook/Instagram Ads: Target users based on interests and demographics.
     • Targeting: Interests: (Small Business, TaxPayers’ Alliance, Federation of Small Businesses), Age: (30+), Location: (United Kingdom).
     • URL: Meta Ads Manager
  3. Use Instagram Reels/Stories: Create short, impactful videos.
     • Reel Idea: A 30-second video showing a pile of money, with text overlays explaining how much was wasted on a specific project. End with a strong call to action.
     • Story Idea: Use the “Quiz” sticker: “How much did [Department] overspend on consultants last year? A) £1M B) £10M C) £100M”. Then reveal the answer and link to your campaign hub.
  4. Sample Facebook Ad Copy:
     

     Image: A graphic with the question “WHERE DID YOUR TAXES GO?”

     Headline: Tired of Seeing Your Money Wasted on Failed Government Projects?

     Text: “Every year, billions of pounds are spent through public contracts. But a lack of transparency and accountability means legitimate businesses are excluded and taxpayer money is wasted. We believe it’s time to hold them accountable. We’re building a collective action to demand change and seek redress. If you’re a UK taxpayer or business owner, your voice is needed. Join the fight.”

     Button: Learn More

     [Link to your Central Campaign Hub]