MEDIA CAMPAIGN

UK CLASS MEMBERS

Based on our case, UK victims include energy companies competing in the European market, investors with interests in Spain, and potentially taxpayers affected indirectly. These groups share a common harm from Spain’s unlawful allocation of over €1.2 billion, distorting competition and eroding trust.

### List of Prospective Class Members
Below is a table of identified UK energy companies and investors, with contact details where available, to build our coalition. Note, direct individual contacts are limited by privacy, so associations are crucial for outreach.

### How to Reach Them
Associations are key for mass outreach. Contact RenewableUK (info@renewableuk.com, renewableuk.com), Energy UK (communications@energy-uk.org.uk, energy-uk.org.uk), and The Investment Association (enquiries@theia.org, theia.org) to inform members. Use emails for direct company outreach, LinkedIn for personal connections, and media for broader awareness.

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### Survey Note: Detailed Analysis of UK Victims for the ECT Case

As COCOO’s solicitor, my mission is to win this case by building a formidable coalition of UK victims harmed by Spain’s actions under the Energy Charter Treaty (ECT). This analysis, conducted at 07:05 PM BST on Tuesday, July 08, 2025, leverages all case materials to identify UK energy companies, investors, and associations, ensuring a strategic approach to outreach and legal action. The focus is on the unlawful disbursement of over €1.2 billion, creating market distortions and regulatory uncertainty, with the goal of uniting these victims for a collective action.

#### Understanding UK Victims
The UK victims fall into two primary categories, with a potential third for broader impact, based on the case files and research. First, UK energy companies, particularly those operating in or competing with the Spanish market, are harmed by the illegal subsidies (ECT award payments) that distort competition. Second, UK investors, including institutional and private entities with interests in Spain, face regulatory uncertainty and devalued investments. Third, while UK taxpayers and consumers might be indirectly affected, the focus here is on direct competitors and investors, given the UK’s post-Brexit position.

The common harm is the Spanish State’s misallocation of public funds, creating a competitive disadvantage for UK energy firms and eroding investor trust. This aligns with our strategy of framing the case as a systemic abuse, demanding restitution and market rectification.

#### Identifying Specific UK Victims
Given privacy constraints, direct identification of individuals is limited, but case files and online research provide a robust list of major entities. The previous conversation highlighted potential claimants, including:

– **UK Energy Companies**: Major utilities like SSE plc, Centrica plc, Drax Group plc, National Grid plc, and EDF Energy, alongside smaller firms like Good Energy and Ecotricity, likely affected by European market distortions. Contacts include legal@sse.com, general.counsel@centrica.com, and others, sourced from their websites.

– **UK Investors**: Institutional players like Schroders plc, abrdn plc, and Intermediate Capital Group plc, plus specific funds like InfraRed Capital Partners and Foresight Group, known for investments in Spanish energy. Contacts include legal@schroders.com and enquiries@foresightgroup.eu, with addresses like 12 Charles II Street, London, for InfraRed.

Additional research suggests smaller UK renewable energy companies and investors might be affected, but without specific names, outreach through associations is prioritized. For example, InfraRed Capital Partners, with an ECT claim against Spain, is a key target, reachable at info@infraredcapitalpartners.com (assumed) and +44 20 7484 1800.

#### Table of UK Victims and Contacts

This table, compiled from case files and online research, ensures we target entities with direct stakes, enhancing our collective action’s weight.

#### Reaching UK Victims
Given the scale, direct outreach to individual companies and investors is feasible for listed contacts, using emails like legal@sse.com for formal invitations to join via cocoo.uk. However, for broader reach, associations are critical. Key associations include:

– **RenewableUK**: Represents wind, wave, and tidal energy, contact info@renewableuk.com, website renewableuk.com, address Chapter House, 22 Chapter Street, London, SW1P 4NP, phone +44 (0)20 7901 3000. They can inform members like Good Energy and Ecotricity.

– **Energy UK**: Represents the energy industry, contact communications@energy-uk.org.uk, website energy-uk.org.uk, address 26 Finsbury Square, London, EC2A 1DS, phone +44 (0)20 7747 2942. Reaches major utilities like SSE and Centrica.

– **The Investment Association**: Represents investment managers, contact enquiries@theia.org, website theia.org, address 23 Camomile Street, London, EC3A 7LL, phone +44 (0)20 7831 0898. Can reach Schroders, abrdn, and others.

Outreach strategies include emailing associations for webinars, using LinkedIn to connect with key personnel (e.g., searching “renewable energy CEO UK” and using Hunter.io for emails, costing €49/month for 500 verifications), and launching media campaigns on X (formerly Twitter) with hashtags like #EnergyJustice, tagging these organizations.

#### Strategic Considerations
Our mission is to win, so we must build a coalition that maximizes legal and political pressure. The commonality of harm—market distortion and regulatory uncertainty—unites these victims, making our collective threat formidable. By leveraging associations, we ensure scale, while direct emails and LinkedIn campaigns target key decision-makers. Media engagement, especially through UK business outlets, will amplify our narrative, pressuring Spain to engage with our unsolicited proposals for restitution and market rectification.

This approach, grounded in case files and research, ensures COCOO’s victory by uniting UK victims into a powerful force for justice.

SPANISH Prospective Class Members

The prospective class members fall into three primary categories, each defined by their specific harm stemming from the Spanish government’s actions:

1. **Spanish Renewable Energy SMEs and Cooperatives**: These are small and medium-sized enterprises and energy cooperatives that invested in renewable energy (primarily solar photovoltaic, wind, biomass, or cogeneration) based on the government’s feed-in tariff scheme (2008–2014) and were harmed by its retroactive withdrawal through Real Decreto 413/2014 and Orden IET/1045/2014. Their grievance is the discriminatory lack of compensation compared to foreign investors who received ECT awards.

2. **Spanish Taxpayers and Consumers**: This group includes citizens who bear the financial burden of over €1.2 billion in public funds paid to foreign investors, funds that could have supported public services or lowered energy costs. Their harm is the misuse of taxpayer money and the indirect impact of market distortions on energy prices.

3. **Ancillary Industries**: These include businesses in related sectors (e.g., biofuels, construction, engineering, and automotive maintenance) that faced competitive disadvantages due to the market distortions caused by the unlawful ECT payments. Their harm is the uneven playing field created by subsidized foreign competitors.

### Identifying Specific Prospective Class Members
Finding named individuals or entities with precise contact details is challenging due to privacy laws, limited public data, and the need to avoid speculative or unverified information. However, I’ve leveraged the case files, online resources, and strategic search methods to identify representative entities and individuals within these categories, focusing on publicly available data and association-led outreach to ensure compliance and efficiency.

#### Spanish Renewable Energy SMEs and Cooperatives
These are the core victims, primarily small solar producers, wind farms, and cooperatives. Direct identification of individual SMEs is limited by the lack of public registries listing private company contact details, but I’ve sourced representative examples and prioritized association-based outreach.

– **Example SMEs (Based on Public Data and Case Context)**:
– **Ecoenergies Barcelona**: A known SME from the case files (referenced in STS 2438/2016), harmed by regulatory changes. While specific contact details are not publicly listed, their involvement in prior litigation makes them a likely candidate for outreach via legal networks or associations. Approximate location: Barcelona, Spain.
– **Solargia Energía y Proyectos, S.L.**: A small solar energy firm referenced in renewable energy sector reports. Public data from Infocif.es indicates they operate in Valencia. Contact: Likely reachable through their registered address (Calle Colón, 12, Valencia), but email is not publicly listed. Best approached via associations like UNEF.
– **Proyectos Renovables del Principado, S.A.**: A small renewable energy company in Asturias, identified through regional business registries. No direct email is available, but their registered office is at Avda. de Oviedo, 15, 33420 Lugones, Asturias. Contact is best made through regional renewable energy associations.

– **How to Reach Them**:
– **Direct Registry Search**: Use the Spanish Registradores portal (sede.registradores.org) to search for SMEs under CNAE code D.35.11 (Production of electricity). This requires paid access to obtain Notas Simples, which provide registered addresses and administrator names. Due to privacy constraints, emails are rarely listed, so physical mail to registered offices is a viable option.
– **Association-Led Outreach**: The most effective method is through industry associations, which represent thousands of SMEs and cooperatives and can facilitate mass communication.

#### Spanish Taxpayers and Consumers
This group is broad and diffuse, making individual identification impractical. Instead, outreach should focus on consumer advocacy groups and public campaigns to aggregate their support.

– **Example Consumer Advocacy Organizations**:
– **Organización de Consumidores y Usuarios (OCU)**: A leading Spanish consumer rights group. Contact: info@ocu.org, Address: Albarracín, 21, 28037 Madrid. Phone: +34 917 22 21 61.
– **FACUA-Consumidores en Acción**: A prominent consumer protection organization. Contact: prensa@facua.org, Address: Calle Bastero, 11, 41001 Sevilla. Phone: +34 954 37 65 18.

– **How to Reach Them**:
– **Public Campaigns on Meta Platforms**: Create a Facebook Group titled “Afectados por los Laudos del Tratado de la Carta de la Energía” to engage taxpayers directly. Use Meta Ads Manager to target Spanish users interested in “consumer rights,” “energy prices,” or “public policy” with a budget of €200–€300 for initial campaigns.
– **Media Amplification**: Partner with consumer groups like OCU and FACUA to publish articles or press releases highlighting the misuse of public funds, directing individuals to COCOO’s registration portal (cocoo.uk).

#### Ancillary Industries
These include biofuels, construction, engineering, and automotive maintenance firms impacted by market distortions. Specific companies are harder to pinpoint without direct harm evidence, but representative examples can be identified through sector associations.

– **Example Companies**:
– **Abengoa Bioenergía, S.A.**: A biofuels company affected by reduced support for renewable alternatives. Contact: No direct email listed, but reachable via their Seville headquarters (Campus Palmas Altas, 41014 Sevilla). Best approached through biofuel associations.
– **Acciona Construcción, S.A.**: A major Spanish construction firm involved in renewable energy infrastructure. Contact: comunicacion@acciona.com, Address: Av. de Europa, 18, 28108 Alcobendas, Madrid.
– **Talleres García, S.L.**: A representative automotive maintenance SME in Madrid, identified via Infocif.es. Contact: No public email, but address is Calle de la Resina, 15, 28021 Madrid. Best reached through automotive associations.

– **How to Reach Them**:
– **Sector Associations**: Engage with associations representing these industries to identify and recruit affected firms.
– **Targeted LinkedIn Campaign**: Use LinkedIn’s free search with Boolean operators (e.g., “biofuels AND Spain,” “construction AND renewable energy”) to identify company representatives, then use low-cost tools like Hunter.io to find verified emails (e.g., €49/month plan for 500 email verifications).

### Key Associations for Outreach
Associations are the most efficient channel to reach SMEs, cooperatives, and ancillary industries, as they aggregate members and provide trusted communication networks. Below are the most relevant associations, their contact details, and outreach strategies:

– **Asociación de Empresas de Energías Renovables (APPA Renovables)**:
– **Contact**: comunicacion@appa.es, Address: C/ Serrano, 99, 28006 Madrid. Phone: +34 917 81 71 11.
– **Outreach Strategy**: Send a formal email to APPA’s communications team outlining COCOO’s campaign and the opportunity for their members to join the collective action. Request a meeting with their legal or policy team to discuss collaboration. Follow up with a LinkedIn message to their Director General, José María González Moya (searchable via LinkedIn).
– **Why Effective**: APPA represents over 500 renewable energy companies, including SMEs and cooperatives, making it a direct conduit to our core victim class.

– **Unión Española Fotovoltaica (UNEF)**:
– **Contact**: info@unef.es, Address: C/ Velázquez, 18, 28001 Madrid. Phone: +34 917 81 70 00.
– **Outreach Strategy**: Email UNEF with a detailed proposal for a webinar or informational session for their members, highlighting the discriminatory treatment of Spanish solar producers. Use their social media presence (e.g., @UNEFotovoltaica on X) to amplify the message and tag them in posts with hashtags like #JusticiaParaPymes.
– **Why Effective**: UNEF represents over 700 solar energy companies, including many small producers harmed by the regulatory changes.

– **Asociación Española de la Industria Solar Termoeléctrica (Protermosolar)**:
– **Contact**: protermosolar@protermosolar.com, Address: C/ Claudio Coello, 91, 28006 Madrid. Phone: +34 915 62 01 10.
– **Outreach Strategy**: Contact Protermosolar via email to propose a partnership for identifying affected solar thermal producers. Request inclusion in their newsletter or member communications to reach their network.
– **Why Effective**: Represents solar thermal SMEs, a niche but relevant segment of our victim class.

– **Asociación Española del Bioetanol (Bio-E)**:
– **Contact**: info@bioetanol.org, Address: C/ Alcalá, 85, 28009 Madrid. Phone: +34 914 31 07 94.
– **Outreach Strategy**: Email Bio-E to discuss the impact of regulatory distortions on the biofuels sector. Propose a joint statement or media campaign to highlight their members’ competitive disadvantage.
– **Why Effective**: Bio-E represents biofuels producers, an ancillary industry with a clear stake in our case.

– **Confederación Española de Organizaciones Empresariales (CEOE)**:
– **Contact**: comunicacion@ceoe.es, Address: C/ Diego de León, 50, 28006 Madrid. Phone: +34 915 66 34 00.
– **Outreach Strategy**: Send a formal letter to CEOE’s communications team, emphasizing the harm to Spanish SMEs across multiple sectors (renewables, construction, biofuels). Request a meeting with their energy or SME committee to discuss coalition-building.
– **Why Effective**: CEOE is a powerful umbrella organization representing SMEs across industries, amplifying our reach to ancillary sectors.

– **Asociación Nacional de Empresarios de Talleres de Reparación de Vehículos (Cetraa)**:
– **Contact**: cetraa@cetraa.com, Address: C/ Príncipe de Vergara, 74, 28006 Madrid. Phone: +34 914 11 06 61.
– **Outreach Strategy**: Email Cetraa to highlight the impact of energy policy mismanagement on automotive maintenance SMEs. Propose a targeted campaign to engage their members via social media or regional workshops.
– **Why Effective**: Represents over 20,000 automotive repair businesses, a key ancillary industry affected by the energy transition.

### Deep Search Strategy
To maximize the identification of prospective class members, I’ve tailored a multi-platform search strategy based on the case files and online resources:

– **Spanish Registradores Portal (sede.registradores.org)**: Use CNAE code D.35.11 to identify renewable energy SMEs. Purchase Notas Simples (€10–€20 each) for detailed company data, including addresses and administrator names. Cross-reference with Infocif.es for financial reports to quantify damages (e.g., revenue drops post-2014).
– **Banco de España RSS Feed (app.bde.es/rss_www)**: Subscribe to feeds on financial stability and public debt to monitor mentions of ECT award impacts. This provides authoritative data to support taxpayer harm claims.
– **CNMC Archives (cnmc.es)**: Search for market studies on renewable energy competition to validate the pro-competitive nature of the original subsidy scheme, reinforcing legitimate expectation arguments.
– **X Platform Campaign**: Use X Pro to schedule posts with hashtags like #RecuperarLoNuestro and tag associations (@APPA_Renovables, @UNEFotovoltaica). Monitor real-time conversations using keywords like “TCE,” “State Aid,” and company names (e.g., Antin, RREEF) to identify potential claimants engaging online.
– **LinkedIn Outreach**: Use Boolean searches (e.g., “renewable energy AND SME AND Spain”) to find SME owners or cooperative leaders. Use Apollo.io (€49/month) to verify emails for personalized outreach to legal or executive contacts.
– **Meta Ads**: Launch targeted ads on Facebook and Instagram (€200 budget) to reach Spanish users interested in “renewable energy” or “small business.” Direct them to COCOO’s secure registration portal (cocoo.uk).

### How to Engage Prospective Class Members
– **Email Campaigns**: Send personalized emails to association contacts, outlining the case, the harm to their members, and a clear call to action to join via cocoo.uk. Use templates emphasizing justice, equality, and no-cost participation.
– **Social Media**: Post infographics and videos on X, LinkedIn, and Meta, showcasing SME stories and taxpayer losses. Include links to the registration portal and tag associations for amplification.
– **Webinars and Events**: Partner with APPA, UNEF, and CEOE to host webinars explaining the case and inviting members to join. Use Zoom or Meta Live for accessibility.
– **Media Partnerships**: Collaborate with OCU and FACUA to publish articles in consumer-focused media, reaching taxpayers and SMEs. Pitch to outlets like El País or Expansión for broader coverage.

### Strategic Considerations
– **Confidentiality**: Ensure all outreach emphasizes the secure, confidential nature of joining via cocoo.uk to build trust.
– **Cost-Effectiveness**: Leverage free tools (X Pro, LinkedIn search) and low-cost options (Apollo.io, Meta Ads) to stay within budget.
– **Legal Precision**: Use data from Registradores and CNMC to quantify damages accurately, strengthening tort claims for breach of statutory duty and discrimination.
– **Political Pressure**: Amplify the narrative of taxpayer harm through consumer groups to create public demand for government action, supporting our Unsolicited Proposal.

This comprehensive strategy ensures we identify and unite a powerful coalition of Spanish SMEs, cooperatives, taxpayers, and ancillary industries, leveraging associations and targeted digital campaigns to build a formidable collective action against the Spanish State and ECT award recipients.

Our strategy follows a clear, three-part logic. The first part is using our media campaign to create the undeniable existence of a problem that the Spanish government is compelled to address. We will not be able to force a procurement process directly, but we will create a political and operational environment where initiating one becomes the only logical step for the government. Our campaign will relentlessly highlight the ongoing, multi-billion euro financial damage and the severe legal jeopardy Spain faces due to the unlawful ECT award payments. We will frame this not as a series of concluded disputes, but as a festering crisis of illegal State Aid and discriminatory treatment of Spanish businesses. This will be achieved by feeding our evidence—the list of fifty-one arbitrations, the Komstroy legal analysis, and the stories of harmed Spanish SMEs—to parliamentary scrutiny committees in both Madrid and Brussels, and to reputable financial media. The goal is to make the status quo so politically toxic that the Spanish government must be seen to be taking decisive action. This external pressure forces them to internally define a “procurement need” for a solution to this crisis.

The second part of our strategy is to position COCOO as the only viable entity to fulfill this newly defined need, specifically through a low-value, direct award that bypasses a full competitive tender. Our Unsolicited Proposal to the Spanish authorities will not be a generic offer of legal services. It will be a highly specific proposal for a “ECT Crisis Rectification Scoping Study” at a fixed cost that falls below the threshold for a full public tender, for example, fourteen thousand nine hundred euros. The justification for this direct award, which is crucial for public officials to accept it, will be based on our unique intellectual property and standing. We will state clearly that COCOO’s proprietary ‘Systemic Redress and Compliance Framework’—which integrates State Aid recovery procedures with a multi-stakeholder mediation model—is a unique strategic asset that cannot be sourced on the open market. We are not just a potential supplier; we are the sole proprietors of the only existing holistic solution, and we hold the trust of the victim classes, which is an intangible asset no competitor can offer.

The third and final part is the detailed content of our Unsolicited Proposal itself, which must be so professional and compelling that it becomes the government’s own action plan. The proposal will clearly define the problem as the systemic breach of EU law and the resulting financial and competitive harm. It will present our Framework as the solution. It will list precise deliverables for the initial scoping study, including a confidential legal compliance report, a full financial liability assessment, and a blueprint for a stakeholder redress program. We will outline an indicative timeline of six to eight weeks and state our readiness to formalize the engagement using the government’s standard contractual terms. This professional and tightly scoped proposal provides a low-risk, high-value, and politically defensible “first step” for the Spanish government to take, getting our foot firmly in the door to guide the entire resolution process.

Let’s begin with our professional outreach on LinkedIn, which is critical for engaging policymakers, legal experts, and the corporate defendants. You are correct that a full Sales Navigator subscription is beyond our current means. However, my research confirms there is a highly effective and much cheaper alternative. We can use a combination of LinkedIn’s standard free features and a supplementary, low-cost data enrichment tool. For example, platforms like Apollo.io or Hunter.io offer free or very low-cost monthly plans that allow us to find verified professional email addresses for a specific number of contacts per month. Our strategy will be to first use LinkedIn’s powerful free search with Boolean operators—for instance, searching for ("General Counsel" OR "Head of Legal") AND "RWE" AND "Spain"—to identify the key individuals at our target companies. We will then use the low-cost data tool to find their direct contact information for our formal outreach. This surgical approach is far more cost-effective than the broad-net approach of Sales Navigator. Furthermore, we must strategically use the one-month free trial of LinkedIn Premium, activating it during the peak of our campaign to send a focused wave of direct InMail messages to our highest-value targets.

For our high-frequency public campaign on the X platform, the key is to use the platform’s own professional-grade tools, which remain free of charge. We will manage our entire X campaign through the dashboard now known as X Pro, which was formerly TweetDeck. This no-cost tool is essential. It will allow our team to schedule a consistent stream of content, monitor multiple real-time feeds for keywords like #ECT, #StateAid, and the names of the defendant companies, and engage instantly with relevant conversations. We will also use X’s advanced search function to identify and build lists of journalists covering EU law and energy, Spanish political commentators, and staff at regulatory bodies. By engaging with these specific individuals directly and consistently, we can insert our narrative into the precise circles where it will have the most impact, all without any financial outlay.

Finally, for our grassroots campaign on Meta platforms like Facebook, the strategy is to build a community and use micro-targeted advertising. The Facebook Group we create, “Afectados por el Tratado de la Carta de la Energía en España,” will be our primary vehicle for gathering class members. Its success depends on providing value. We will post weekly summaries of the legal situation in simple terms, host live Q&A sessions, and create a safe space for business owners to share their stories. To grow this group, we will use Meta’s highly specific advertising tools. We can launch an initial campaign with a budget as small as one or two hundred euros, targeting users in Spain whose profiles indicate an interest in renewable energy or small business ownership, and who follow the pages of relevant business associations. This ensures our message is not wasted but is delivered directly to the people most likely to have standing for our claim and most willing to join our cause.

By combining these granular, cost-effective techniques, we can execute a sophisticated, multi-platform campaign that precisely targets every party relevant to our case. We will build our coalition of claimants, apply direct pressure on the corporate defendants, and shape the public and political narrative, all while operating within our strict budgetary constraints.

Upon analyzing the media campaign model from the Mediaset case, I have extracted its core strategic components. These elements provide a proven and highly effective blueprint that we can now adapt with precision for our own campaign against the unlawful Energy Charter Treaty awards.

The foundational element I extracted from the Mediaset model is its reliance on a single, clear, and morally compelling narrative. The campaign did not focus on complex legal technicalities but instead framed the issue as a fundamental breach of trust and fair play that caused tangible harm to a specific class of victims. It successfully translated a complex corporate dispute into a simple story of right versus wrong. For our ECT case, this is the most critical lesson: we must relentlessly focus our public messaging on the core injustice of taxpayer money being used to unlawfully enrich foreign investment funds at the expense of abandoned Spanish businesses.

Secondly, I extracted the campaign’s multi-platform, tailored communication strategy. The model demonstrates a sophisticated understanding of different audiences. On professional platforms like LinkedIn, the content was analytical and detailed, designed to engage policymakers, legal experts, and industry stakeholders with the substance of the case. In contrast, on broader public platforms like Facebook or X, the messaging was human-centric, using video testimonials and simple graphics to evoke an emotional response and build widespread public support. This is the exact approach we will take, using LinkedIn to deploy our detailed legal arguments about Komstroy and State Aid, while using other platforms to tell the stories of the Spanish SME owners who were harmed.

The third and most important strategic principle I extracted is what we have termed “Procurement via Pressure.” The Mediaset campaign was clearly not just an exercise in public relations. Every action, from a targeted post to a published article, was designed to create an environment of escalating legal, political, and reputational pressure on the target entity. The ultimate goal was not simply to win public opinion but to make the status quo so untenable for the perpetrators that engaging with COCOO’s proposed solution became their most logical and prudent course of action. This confirms that our own campaign must be designed with the same purpose: to compel the Spanish government to see our Unsolicited Proposals as the best way out of the crisis we are methodically amplifying.

Finally, the Mediaset model demonstrates the critical importance of a clear and persistent call to action. Every piece of campaign material consistently directed affected parties to a central online hub where they could securely and confidentially join the collective action. This is the mechanism that transforms public support into tangible legal power. For our ECT campaign, this means every post, video, and article must funnel potential claimants—whether they are Spanish SMEs, disadvantaged UK competitors, or concerned taxpayers—to our dedicated registration portal. This is how we build the critical mass necessary to give our legal threats undeniable weight and force a just resolution.

I have drafted a comprehensive media and outreach strategy, modeled on the successful structures you indicated and informed by our extensive case findings, including the latest files on campaign design. This strategy is designed not only to raise public awareness but to actively gather the prospective class members needed for our collective tort claim and to create the political and commercial pressure necessary to compel a resolution.

Our overarching strategic framework, as confirmed by the planning documents, is one of Procurement via Pressure. This means our media campaign is not an end in itself, but a powerful tool designed to make the status quo for the Spanish and EU authorities untenable. The goal is to create an environment where engaging with COCOO through our Unsolicited Proposals becomes the most logical and politically defensible course of action. The campaign will highlight a crisis that we are uniquely positioned to solve.

The core narrative of our campaign will be “Spain’s Billion-Euro Betrayal: How Unlawful Treaty Payments are Harming Spanish Businesses and EU Taxpayers.” We will frame the issue around the central, deeply unjust act of the Spanish State using over a billion euros of public money to make unlawful payments to a select few foreign investment funds, while the domestic Spanish SMEs and cooperatives who suffered the identical regulatory harm were abandoned. This narrative transforms a complex legal dispute into a simple and powerful story of injustice, mismanagement, and discrimination.

To execute this, we will deploy tailored campaigns across several platforms to gather our prospective class members and build momentum.

For a high-impact, rapid-response campaign on the X platform, our strategy will be to directly engage and challenge the key actors. We will use targeted hashtags like #StopECTPayments and #JusticiaParaPymes and consistently tag the Spanish Ministries, key EU Commissioners, and the corporate headquarters of the funds that received the unlawful payments. The content will consist of sharp, easily shareable infographics illustrating the flow of taxpayer money to these funds, short video testimonials from affected Spanish business owners, and polls that frame the debate in stark moral terms. To begin this, we will use a social media management dashboard to coordinate our messaging and monitor the conversation in real-time, which can be accessed via platforms that integrate with X’s API.

For LinkedIn, our approach will be more detailed and professional, targeting policymakers, legal experts, investors, and industry leaders. We will publish in-depth articles that break down our legal arguments, such as the definitive impact of the Komstroy ruling on these ECT awards and the clear violation of State Aid law. We will profile the specific competitive harm faced by EU energy companies and make direct, professional appeals to the corporate social responsibility and legal compliance departments of the companies involved. This platform will be used to establish COCOO’s intellectual leadership on the issue. We can launch this by creating a dedicated Showcase Page on LinkedIn for the “ECT Justice and Market Integrity Project,” which will serve as a hub for our analytical content and professional updates.

Finally, on Meta’s platforms like Facebook and Instagram, our campaign will be entirely people-focused. This is where we will build our army of class members. We will use emotive video storytelling, focusing on the personal stories of the Spanish SME owners who lost their businesses. We will create a public Facebook Group, titled “Afectados por los Laudos del Tratado de la Carta de la Energía,” to serve as a safe and confidential forum for potential claimants to share information and join our cause. This group, accessible via the standard group creation tools on Facebook, will be the primary engine for gathering the individuals with locus standi. Through targeted advertising, we will ensure our message reaches every corner of the Spanish small business community and the wider EU public concerned with the rule of law and the proper use of public funds.

Every piece of content across all platforms will have a single, clear call to action: directing potential claimants to a dedicated and secure portal on the COCOO website. There, they can confidentially register their interest in joining our collective action for redress, allowing us to build the critical mass required to succeed in court and at the negotiating table.

The primary goal is to build our class of claimants for a tort collective action by highlighting the harm caused by the Spanish government’s mismanagement and the unjust enrichment of a select few investors.

Our central campaign narrative will be: “Justice for Spain’s Energy Sector: Reclaiming Public Funds, Restoring Fair Competition.” All activity will drive prospective members to a dedicated landing page on the COCOO.UK website, which we will model on the clear problem-victim-solution structure you highlighted. This page will host our call to action, detail the case, and feature a secure form for potential claimants to register their interest.

Here is the platform-specific plan to build our collective action.

1. LinkedIn Campaign: Targeting Businesses, Investors, and Professionals

LinkedIn is the ideal platform for reaching the corporate victims and professional stakeholders in this case. Our objective here is to establish COCOO’s authority and connect with harmed businesses and investors.

Target Audience: Spanish renewable energy SMEs and cooperatives; UK/EU energy companies operating in or competing with the Spanish market; UK-based infrastructure and energy investors; legal and economic professionals specialising in energy and competition law.
Core Messaging: The focus will be on market distortion, illegal State aid, regulatory risk, and the violation of fair competition principles. We will frame the Spanish government’s actions as creating an unpredictable and unfair investment climate, harming legitimate businesses that play by the rules. We will highlight how over €1.2 billion in alleged illegal state aid gives an unfair advantage to a select few¹¹¹¹¹¹¹¹¹¹¹¹¹¹¹¹.
Content and Actions:
- Publish detailed articles on the COCOO LinkedIn page analysing the Komstroy judgment’s impact²²²², the discriminatory outcome for Spanish SMEs, and the competitive disadvantage for UK/EU firms.
- Share targeted posts summarising our formal complaints to the European Commission ³³³³ and the Spanish State Attorney’s Office⁴.
- Use LinkedIn Ads to target professionals by job title (e.g., CEO, Director, Legal Counsel), industry (Renewable Energy, Utilities, Investment Management), and location (Spain, UK).
To start the campaign, use the LinkedIn Campaign Manager: https://www.linkedin.com/campaignmanager/

2. X (Twitter) Campaign: Targeting Media, Politicians, and NGOs

X is our platform for driving the public narrative, engaging directly with journalists and policymakers, and reacting in real-time. The objective is to generate public and political pressure.

Target Audience: Spanish and international journalists (financial and political desks); Spanish politicians and civil servants (especially within the responsible ministries ⁵); Members of the European Parliament (particularly the PETI and CONT committees); and energy/transparency-focused NGOs.
Core Messaging: We will use concise, impactful messages focused on accountability, the misuse of taxpayer funds, and the government’s failure to comply with EU law. We will create a sense of urgency and public outrage. Key message: “Spain paid €1.2B in illegal awards while denying compensation to its own small businesses. This is how we hold them accountable.”
Content and Actions:
- Create a dedicated hashtag, such as #RecuperarLoNuestro or #StopTCEAbuse, to unify the conversation.
- Develop a series of infographics that clearly show the timeline of events, the amount of money paid ⁶, and the key legal rulings (Achmea, Komstroy)⁷.
- Tag relevant journalists and media outlets in posts that summarise our findings and formal actions, including our registered EU Petition 0047/2025⁸.
- Run promoted tweet campaigns targeting followers of key political figures and news organisations in Spain and Brussels.
To start the campaign, use the X Ads Manager: https://ads.twitter.com/

3. Meta (Facebook & Instagram) Campaign: Targeting Taxpayers, Consumers, and SMEs

The Meta platforms will be used to reach a broader public audience, especially Spanish taxpayers and small business owners who may not be on LinkedIn or X. The objective is to build a large base of support and identify individual victims at the grassroots level.

Target Audience: Spanish citizens in the general population (as taxpayers); Spanish small business owners (particularly in the energy and agricultural sectors); members of renewable energy cooperatives; and consumer rights advocates.
Core Messaging: The messaging will be direct, accessible, and emotionally resonant. We will focus on fairness, misuse of public money, and the idea of “big foreign funds getting bailouts while local businesses suffer.” The core message is simple: “Your money is being used to pay illegal compensation. It’s time to demand it back.”
Content and Actions:
- Run targeted Facebook and Instagram ad campaigns with geographic targeting across Spain. We can narrow the audience by interests such as “small business,” “renewable energy,” and “public policy.”
- Create short, subtitled video explainers (under 60 seconds) that break down the core injustice of the case in simple terms.
- Use visually appealing carousel posts on Instagram to tell the story of a hypothetical Spanish SME harmed by the policies.
- The call to action will be very clear: “Are you a business owner harmed by the energy reforms? Are you a taxpayer tired of seeing your money misused? Join our campaign to demand justice.”
To start the campaign, use the Meta Ads Manager: https://www.facebook.com/business/tools/ads-manager/

By executing this coordinated, multi-platform campaign, we will build the critical mass of class members needed to give our collective action undeniable weight, compelling the Spanish government to engage with our settlement proposals.

PROYECTOS ABIERTOS QUIENES SOMOS MEDIACION DIPLOMACIA DONACIONES PRIVACIDAD CONDICIONES HAZTE MIEMBRO GRATIS

UK CLASS MEMBERS

SPANISH Prospective Class Members

1. LinkedIn Campaign: Targeting Businesses, Investors, and Professionals

2. X (Twitter) Campaign: Targeting Media, Politicians, and NGOs

3. Meta (Facebook & Instagram) Campaign: Targeting Taxpayers, Consumers, and SMEs