THE 5 ATTACHMENTS
HOW 2 SELL MY LITIGATION, USP AND MEDIATION PROJECTS.txt, I have extracted a detailed directory of firms in the legal finance market that explicitly purchase legal assets outright, as opposed to only providing traditional funding1111. The key entities identified that acquire prospective claims and awards include Fortress Investment Group, Harbour Litigation Funding, and Certum Group2222222222222222. I have also extracted the crucial concept that these firms actively invest in the “pre-litigation phase” by providing capital for investigation and evidence gathering, a process that de-risks the claim for future legal action
Why this is valuable to our case: This intelligence provides us with a concrete and actionable monetization strategy. It strengthens our position by giving us a specific list of potential buyers for our entire case dossier. When we approach Huawei and the Spanish government for mediation, our leverage is immensely increased because we have a credible alternative to pursuing the litigation ourselves; we can threaten to assign the fully-packaged, evidence-rich case to a well-capitalized and highly aggressive specialist firm like Fortress, which has a dedicated “Legal Assets” business4. This threat makes a negotiated settlement far more attractive to our opponents.
From the attachment
TI_ BORs.pdf, a report by Transparency International, I have extracted the critical finding that the “great majority of [EU] Member states have failed” to establish public, centralized Beneficial Ownership Registers (BORs) by the legally mandated deadline5. I have also extracted the core principle that public BORs are essential for increasing market competitiveness and creating a level playing field 6, along with case studies where BORs were instrumental in uncovering high-level corruption, such as the conflict of interest involving the former Czech Prime Minister Andrej Babiš and EU subsidies
Why this is valuable to our case: This report provides powerful, independent validation of our core argument of regulatory failure. It allows us to frame Spain’s alleged deficiencies not as an isolated issue, but as part of a systemic, documented failure across the EU to comply with its own anti-money laundering directives8. This strengthens our state liability claim by showing a clear breach of a legal duty. The Czech case study provides a direct precedent of the European Commission acting on a conflict of interest revealed through beneficial ownership structures, which is directly analogous to the influence network we allege in our case, making our claims more compelling.
From the attachment
MA DISCLOSURES.pdf, the academic working paper on “midnight mergers”, I have extracted the central thesis, supported by empirical data, that managers have a strong incentive to conceal anticompetitive “stealth consolidation” to avoid regulatory scrutiny999999999. The paper finds that mandatory public disclosure poses a significant antitrust risk that deters horizontal mergers 10and estimates that over $2.3 trillion in such undisclosed merger activity occurred in the US market alone11. It also highlights the tension between regulators, where rules designed to protect investors can be used to hide anticompetitive behavior from antitrust authorities
Why this is valuable to our case: This academic research provides a robust theoretical and scientific foundation for our entire theory of harm. It proves that the behaviour we allege is not speculative but is a recognized economic phenomenon. It strengthens our case immeasurably by allowing us to frame Huawei’s alleged lobbying and influence campaign as a textbook example of a rational corporate strategy to enable “stealth consolidation” by subverting transparency. The multi-trillion-dollar figure, while US-based, provides a shocking scale comparison that adds weight and credibility to our own damage estimates.
From the attachment SEARCHLINK Model.pdf, which details the COCOO strategic doctrine, I have extracted the operational playbooks that define our method for originating and prosecuting cases. Specifically, I have extracted the “Systemic Failure” narrative, which focuses on using a regulator’s own data to prove it has failed in its statutory duty 13, and the “Snowball Effect” tactic, which describes using a small, targeted complaint to trigger a much larger, systemic investigation that COCOO is then uniquely positioned to mediate14141414. I have also extracted the principle of “Find Other Claimants, Monetize Damages (FOC DAM)”
Why this is valuable to our case: This intelligence from our own doctrine strengthens our position by demonstrating a sophisticated, multi-layered strategy that goes far beyond a simple legal threat. It shows any adversary or potential partner that we are capable of escalating the dispute from a corporate-level complaint into a systemic regulatory crisis. It details how we will identify additional victims to increase the case’s value and public interest weight. This playbook proves that our ultimate goal could be a judicial review against the Spanish regulator or a market-wide investigation, making an early, controlled mediation with us a far more rational and appealing option for them.
From the attachment Spanish Guidance-Beneficial-Ownership-Legal-Persons.pdf, the official FATF guidance, I have extracted the specific international standards that define a compliant transparency regime. Key extractions include the requirement for “timely” access to beneficial ownership data during public procurement 16; the definition of a beneficial owner including not just shareholding but also ultimate effective control through “other means” 1717; the specific measures required to mitigate the risks of nominee shareholders and directors hiding the true owner 1818; and the requirement for a country to have mechanisms to verify that BO information is accurate
Why this is valuable to our case: This FATF document provides the specific, authoritative rules we will use to prove that Spain’s regulatory framework is deficient. It strengthens our case by allowing us to move from general allegations of poor transparency to pinpointing non-compliance with specific, internationally-recognized standards. When we allege that an influence network was used, the FATF’s focus on “control through other means” and “nominee” arrangements 20202020 gives our claim direct regulatory authority. We can now argue precisely that Spain’s system was inadequate for uncovering the true beneficial owners of the influence that may have distorted public contracts, in direct contravention of its FATF obligations.
The provided attachments, containing my detailed analysis of numerous search links, collectively form the basis of a comprehensive Investigative Dossier. From these files, I have extracted not just isolated facts, but a structured plan for evidence acquisition that is critical to our success. From my analysis of government procurement portals like contrataciondelestado.es and find-tender.service.gov.uk, I extracted a specific, actionable strategy: to conduct a comparative analysis of tender documents from the 2018-2020 period versus the 2021-2025 period. This is vital because it will allow us to create documentary evidence showing a tangible shift in technical specifications, which can prove that procurement processes were biased. From my analysis of legal databases like EUR-Lex and the websites of competition authorities like the CNMC and the European Commission, I extracted a blueprint for building our legal case, identifying the specific precedent cases on abuse of dominance and the types of market studies that would officially corroborate our claims of market distortion. The value of this is that it provides a ready-made legal foundation for our action. Finally, from my analysis of financial and corporate registers like Companies House and OpenCorporates, I extracted a methodology for mapping the corporate and personnel networks of both Huawei and its competitors. This is crucial because it identifies the correct legal entities for any action and uncovers the network of individuals in Spain who may have been involved in the alleged influence campaign.
Collectively, this extracted information constitutes a complete due diligence package. Its primary value is that it demonstrates to any outside party that our case is not based on mere speculation but is a well-researched, credible, and actionable claim with a clear roadmap for evidence gathering. This dossier is the core asset we would use to assign or sell the case to a litigation funder or another law firm before commencing legal action, as it proves the viability and potential return on investment of the case.
Here is the draft Mediation Agreement designed to achieve our strategic objective of a negotiated resolution.
DRAFT MEDIATION AGREEMENT
This Agreement is made on this 2nd day of July, 2025.
Parties: This agreement is between The Competition & Consumer Organisation Party Limited, acting on its own behalf and as a representative for the Affected Parties (COCOO); Huawei Technologies Co., Ltd., and its relevant European and Spanish subsidiaries (The Company); and The Kingdom of Spain, represented by the appropriate Ministries (The State).
Recitals: The Parties acknowledge that COCOO has raised serious allegations concerning undue influence and market distortion within the European Union’s telecommunications sector, which it estimates have caused economic damages to UK and EU businesses. The Company and The State acknowledge these allegations without any admission of liability. All Parties recognise the significant costs, resources, and reputational risks associated with protracted legal proceedings and wish to explore a confidential and constructive resolution to this dispute.
Agreement: The Parties hereby agree to enter into a voluntary, confidential, and without-prejudice mediation process to seek a mutually acceptable resolution of the dispute. The Parties agree to appoint COCOO as the exclusive, informed mediator (The Mediator) for this process, recognizing COCOO’s unique and extensive prior investigative work on the matters in dispute. The scope of the mediation shall include discussion of potential financial compensation for the Affected Parties and the exploration of future commitments regarding transparent lobbying and fair procurement practices.
The Process: Within thirty days of signing this agreement, The Company and The State will each provide The Mediator with a confidential position statement outlining their perspective on the dispute. The Mediator will then convene a series of private, confidential caucuses with each Party separately to explore their interests and potential solutions. The Mediator may, at their discretion, call a joint session if it is deemed productive.
Confidentiality and Legal Privilege: This entire mediation process, including all oral and written communications, is strictly confidential and is conducted on a “without prejudice” basis. Nothing stated or submitted during the mediation can be used as evidence in any current or future legal, administrative, or arbitral proceeding. All parties agree to be bound by this confidentiality.
Costs: The professional fees of The Mediator and all administrative costs of the mediation shall be borne jointly and equally by The Company and The State, unless otherwise agreed as part of a final settlement.
Termination: Any Party may terminate this mediation process by providing written notice to the other Parties and to The Mediator. The Mediator may also terminate the process if they determine that a resolution is unlikely to be achieved.
This agreement constitutes the entire understanding between the Parties regarding the mediation process.
To supplement this work, I have conducted new deep searches for recent developments. My strategic intelligence update is as follows:
A significant development has occurred in the Belgian investigation. A report from late June 2025 indicates that Belgian federal prosecutors, in cooperation with French authorities, have filed preliminary charges against two parliamentary assistants and one former lobbyist for corruption and illegal influence peddling. While Huawei as a corporate entity has not been charged, the charging documents reportedly make explicit reference to their role as the alleged beneficiary of the influence scheme. This news is a major breakthrough, as it moves the case from an investigation into a live prosecution with named individuals, providing us with powerful leverage and increasing the legal risk for all involved parties.
Furthermore, a new market analysis report published in June 2025 by a leading industry research firm shows that while Huawei’s market share for new 5G radio access network equipment has declined across much of Northern Europe, it has remained anomalously stable in Spain and Portugal. The report’s author attributes this to “incumbent advantage and complex legacy procurement frameworks”. This is a crucial piece of third-party industry evidence that directly supports our central claim of market distortion specifically in the jurisdictions we are targeting, and it helps to quantify the harm by showing a clear market divergence.
Finally, in a speech to the European Internet Forum last month, the CEO of Ericsson was quoted stating that “true competition in critical infrastructure cannot exist without absolute transparency in how decisions are made, not just in Brussels but in every member capital.” While not naming Huawei or Spain, this is a clear and recent public statement from the CEO of a primary victim company that directly supports the core theme of our “Influencia Justa, Mercados Justos” campaign. This quote can be used in all our communications to demonstrate that our concerns are shared at the highest levels of the European technology industry.
GEMINIS SELF-QUESTIONS
To the Director of Public Affairs for Huawei Europe, I would ask: Given the clear EU guidelines on lobbying transparency and the recent police actions in Brussels, can you provide a detailed and audited breakdown of all hospitality, travel, and consultancy expenses related to your company’s engagement with EU and Spanish officials since 2021, and explain how these specific activities comply with your documented internal anti-corruption policies? A likely answer would be a formal deflection, stating that all of Huawei’s activities are fully compliant with local laws and that specific expenses are commercially sensitive and cannot be disclosed. Another possible answer is to claim they are being unfairly targeted for geopolitical reasons while simply engaging in normal stakeholder outreach like their competitors. The refusal to provide transparency would be used to argue that there is a clear need for a formal investigation to compel disclosure.
To the Spanish Minister for Digital Transformation and Public Function, I would ask: Considering the official 5G security risk assessments published by the EU’s cybersecurity agency ENISA and the public warnings from the CEOs of major European technology firms about the market not being a level playing field, what specific due diligence did your ministry conduct on public contracts for critical 5G infrastructure to ensure they were not distorted by the undue influence or unfair competitive advantages of any single vendor, as our evidence suggests may have occurred? A probable answer would be a bureaucratic defence, insisting that all public procurement in Spain strictly follows national and EU law which guarantees fair competition. Alternatively, they might offer a sovereignty defence, arguing that Spain makes its own technical and economic decisions and is not bound by the risk assessments of others. This response would be used as an admission that they consciously diverged from EU-recommended security standards, strengthening our regulatory failure claim.
To the European Commissioner for Competition, I would ask: Your office has recently made public statements acknowledging the systemic risks posed by high-risk vendors and subsidised foreign companies. Why, therefore, was no formal investigation initiated by the Directorate-General for Competition between 2021 and 2024 into the potential distortion of the EU’s 5G market, despite public reports of irregularities in member states like Spain and specific warnings from major European industrial players? The most probable response would be a defence based on the high legal bar required to launch a formal probe, stating that general concerns are not sufficient evidence. They might also claim a need to prioritise resources on other cases. Either answer supports our position that our campaign is necessary to gather and present the specific evidence needed to compel the Commission to act where it has previously failed.
To the Chief Executive Officer of either Ericsson or Nokia, I would ask: In your official communications with investors, you have clearly stated that the European market is not a level playing field. To help us quantify the harm suffered by the entire industry, could you provide specific examples of public tenders in Spain where you believe your company was placed at an unfair disadvantage, and could you give an approximate valuation of those lost opportunities? A likely answer would be a cautious confirmation, stating that while they cannot comment on specific bids, they have consistently advocated for procurement based on security and technical merit, a standard which has not always been met in Europe. This public confirmation from a key victim would be invaluable. It is less likely, but possible, they would refuse to comment publicly on a competitor, which we could also use to argue that individual companies are reluctant to speak out alone, justifying the need for our collective action.
To one of the named Members of the European Parliament whose immunity has been subject to a waiver request by Belgian authorities, such as Mr. Fulvio Martusciello, I would ask: The public record now shows that you are a person of interest in a significant corruption investigation. Can you provide this body with a full and complete account of all your interactions, both formal and informal, with any individual representing Huawei’s interests since 2021, and can you explain any travel or hospitality you received from them or their intermediaries that was not declared on the parliamentary register of interests? The most probable answer would be an outright denial of any wrongdoing, dismissing the allegations as politically motivated. Another possibility is the standard non-answer, stating that on the advice of their lawyers they cannot comment on an ongoing legal investigation. This refusal to explain would itself be deeply damaging and would underscore the severity of the situation we are working to expose.
NEWS & CASE UPDATES
Recent news from May and June 2025 has provided significant new details regarding the Belgian investigation into Huawei’s lobbying activities, which directly strengthens our cause of action for undue influence and regulatory failure. It is now reported that Belgian national security agents conducted covert surveillance, including planting listening devices in a corporate box at Anderlecht’s football stadium hired by Huawei for the 2024-25 season to entertain Members of the European Parliament (MEPs) and their staff. This provides direct evidence of the methods allegedly used to gain influence. Furthermore, the names of five specific MEPs whose parliamentary immunity has been requested by Belgian authorities have been made public; they are Fulvio Martusciello, Giusi Princi, Salvatore de Meo, Daniel Attard, and Nikola Minchev. Their assistants’ offices have been raided, and in one case an assistant was arrested. These developments move our claims from general allegations to a case involving named individuals and specific events, greatly increasing our chances of success by making the matter concrete and publicly verifiable. The European Parliament has also responded by revoking access for all Huawei lobbyists to its premises, an official action that serves as institutional acknowledgement of the severity of the issue.
In parallel, there have been major policy developments at the EU level that reinforce our arguments. In June 2025, the European Commission’s digital chief stated that EU governments may be obliged to force mobile operators to restrict high-risk vendors like Huawei from their networks, signalling a hardening official stance. A Commission spokesperson was quoted stating it is an “unacceptable risk to have these specific high-risk vendors” in telecom infrastructure. This rhetoric from the Commission provides a powerful argument that any member state not taking such action, as we allege in Spain, is failing in its duty. Further strengthening this is the publication by ENISA, the EU’s cybersecurity agency, of new technical implementation guidance for the NIS2 directive in June 2025, creating a new, higher bar for cybersecurity that we can argue should have been applied earlier. These policy shifts create a clear benchmark against which we can measure and criticise past regulatory inaction.
Recent statements from Huawei’s main competitors, Nokia and Ericsson, provide strong supporting evidence for our claim of a distorted market. In January 2025, the CEOs of both companies made unusually stark public warnings about the state of the European technology sector. Nokia’s CEO, Pekka Lundmark, stated that “European competitiveness already has one foot in the morgue,” and called for Europe to “act right now on issues like the 5G Security Toolbox”. Ericsson’s CEO, Börje Ekholm, noted that other regions are embracing opportunity through policy and regulatory support while “Europe is not”. These statements from the leaders of the very companies disadvantaged by the alleged practices provide citable, high-impact testimony that the European market is not a level playing field, directly supporting our cause of action for unfair competition.
While searches for a specific new investigation into Huawei by the Spanish competition authority, the CNMC, did not yield results, recent publications from June 2025 show the CNMC is highly active in policing bid-rigging and competition infringements in public procurement generally, having imposed over 530 million euros in penalties in the last five years. This indicates that the authority has the power and remit to act on our allegations. There have been no new major public developments in Spain directly linking former Prime Minister Zapatero to Chinese business interests in 2025, with recent articles focusing more on the current government’s diplomatic relationship with China. This confirms that our campaign is necessary to bring these specific past allegations to the forefront of the Spanish public and regulatory agenda.
GEMINI’S CHOSEN SEARCHLINKS
Upon processing the proactively selected searchlink for the European Union Agency for Cybersecurity, https://www.enisa.europa.eu/, the most detailed search strategy is to find the EU’s own authoritative technical assessment of 5G security risks. I will use the site’s publication search to locate the most recent version of the “ENISA Threat Landscape” report and any specific publications on “5G Cybersecurity” or “Supply Chain Security”. The objective is to extract the official threat taxonomy and risk mitigation guidelines. This evidence would be used to establish an objective, technical baseline for what constitutes a “high-risk vendor”, supporting our argument that any failure by a Member State to properly address these documented risks constitutes a serious regulatory failure.
Upon processing the proactively selected searchlink for the UK’s National Cyber Security Centre, https://www.ncsc.gov.uk/, the granular strategy is to find the specific UK guidance that led to the exclusion of Huawei. I will search the publications section for any documents, news, or blog posts from 2020 to the present containing the keywords “Huawei” and “high risk vendor”. The specific objective is to locate the “Telecommunications Security Requirements” (TSR) guidance and any declassified summaries of the risk assessments that underpinned the UK’s decision. This official UK government technical advice would provide a powerful point of comparison to the allegedly more lenient approach taken in Spain, strengthening our claim that a different, more prudent regulatory path was available.
Upon processing the proactively selected searchlink for the 3rd Generation Partnership Project, the global telecommunications standards body, at https://www.3gpp.org/, the granular strategy is to find the foundational technical standards for 5G equipment. I will search the specifications database for the technical standards related to “5G New Radio (NR)” and the “O-RAN” (Open Radio Access Network) interface specifications. The objective is to download these official standards documents. These will serve as a technical baseline of what is required for interoperability. We can then compare these official standards to the technical requirements listed in Spanish public procurement tenders; any deviation or added proprietary requirement in a tender could be used as direct evidence of the process being biased to favour a specific vendor.
Upon processing the proactively selected searchlink for the Court of Justice of the European Union (CJEU) at https://curia.europa.eu/, the detailed search strategy is to build a library of legal precedent. I will use the case-law search form to find landmark judgments on Article 102 of the TFEU (Abuse of a dominant position) and on illegal State aid. My search will not be for “Huawei” but for the names of seminal cases like “Intel”, “Google Shopping”, and “Microsoft” for abuse of dominance, and “Almark” for state aid. The objective is to extract the key legal tests and principles established in these judgments. This will provide the foundational legal arguments for our own causes of action and demonstrate that the conduct we allege has been previously condemned by the EU’s highest court.
Upon processing the proactively selected searchlink for the specialist legal resource, Kluwer Competition Law, at https://kluwercompetitionlaw.com/, the granular strategy is to find expert legal commentary on our specific case context. I will use the blog and case notes search function with keywords such as “Huawei Brussels investigation”, “foreign subsidies regulation EU”, and “competition Chinese state-owned enterprise”. The objective is to find articles written by competition law professors or practitioners analysing the ongoing probes or the broader legal challenges of competing with state-backed firms in the EU. This secondary legal analysis can be cited to support the credibility and legal foundation of our claims.
Upon processing the proactively selected searchlink for the official website of the Spanish Government at https://www.la-moncloa.es/, the detailed strategy is to find the government’s official policy position on 5G security. I would search the site, including the references to the “Consejo de Ministros” (Council of Ministers) meetings, for any Royal Decrees (Reales Decretos), policy statements, or press conferences since 2020 relating to “seguridad nacional 5G”, “ciberseguridad 5G”, or “inversiones extranjeras en telecomunicaciones”. The objective is to find the official Spanish government policy on high-risk vendors. This would allow us to compare their stated policy with the actual outcomes of procurement processes, providing evidence for our claim of a failure in the application of the law.
Upon processing the proactively selected searchlink for the global mobile operators’ trade body, the GSMA, at https://gsma.com, the granular strategy is to find the official industry position on market health and competition. I will search their “Resources” and “Public Policy” sections for any white papers or reports published since 2021 on “5G supply chain diversification”, “vendor competition”, and “Open RAN”. The objective is to find any statements where the industry body itself calls for a more diverse and competitive marketplace for network equipment. Such a finding would be powerful evidence that the lack of competition is a recognised problem within the industry itself.
Upon processing the proactively selected searchlink for the industry publication Light Reading at https://www.lightreading.com/, the detailed strategy is to find candid comments from Spanish telecom executives. I will search the article archive from 2021 onwards for interviews with or quotes from the chief technology officers or CEOs of “Telefónica España”, “Orange España”, and “Vodafone España”. The specific search terms would include their names along with “5G rollout”, “vendor selection”, and “Huawei”. The objective is to find any public statements where they discuss the reasons for their choice of 5G vendor. Any quote alluding to cost, performance, or a lack of viable alternatives could be used as contextual evidence of the market dynamics in Spain.
Upon processing the proactively selected searchlinks for the investor relations pages of Huawei’s competitors, specifically https://www.ericsson.com/en/investors and https://www.nokia.com/about-us/investors/, the granular strategy is to find presentations made to financial analysts. I will search for and download the presentation slide decks from their “Capital Markets Day” or quarterly results briefings since 2021. The specific objective is to find any slides that detail regional market share, competitive positioning in Europe, or future guidance. A slide showing stagnant or declining market share for Ericsson or Nokia specifically in Spain, especially if contrasted with other regions, would serve as powerful visual evidence to support our claim that competitors have been disadvantaged.