MEDIA CAMPAIGN

                         

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a media campaign strategy designed to engage prospective class members for our tort collective claim, driving them to our campaign website, COCOO.UK, to seek redress. The strategy is tailored to the specific causes of action we have uncovered and structured for a phased, multi-platform execution.

Our core strategy is to build a powerful public narrative around the central theme of fairness and accountability. The message is simple: UK consumers and businesses should not be financially disadvantaged by the corporate governance failures and political entanglements of a foreign parent company. We will translate the complex legal causes of action—such as misfeasance in public office related to the Spanish state’s investment and tortious interference in business—into a relatable story of potential consumer harm, focusing on unfair pricing, reduced service quality, and stifled innovation at Virgin Media O2.

The campaign will unfold in three distinct phases. Phase One is “Awareness and Intrigue,” where we introduce the core problem to the public. We will focus on educating consumers about the new ownership structure of Telefónica and pose critical questions about its impact on VMO2’s service in the UK. Phase Two is the “Call to Action,” where we directly recruit class members using targeted advertising that leverages the call to action we have already drafted, driving traffic to the registration page on the COCOO.UK website. Phase Three, “Amplification and Pressure,” will use the momentum of initial sign-ups to generate media coverage and apply public pressure on the defendants.

For the Meta platforms, including Facebook and Instagram, our approach will target the broad base of VMO2’s consumer customers. We will use Meta’s Ads Manager to create visually compelling video and image-based campaigns. The content will be direct, asking questions like “Are you paying too much for your mobile and broadband?” and will briefly explain how events overseas could be affecting their bills. Our targeting will focus on UK users who have shown an interest in Virgin Media, O2, or other telecommunications providers. The primary goal here is lead generation, driving users to our sign-up page. You can begin setting this up at business.facebook.com/adsmanager, where you will select “Leads” or “Traffic” as your campaign objective.

On the X platform, our strategy will be to engage with journalists, politicians, and tech-savvy consumers. This is where we will connect the dots more explicitly between the Spanish government’s actions and the potential harm to UK interests. We will use threads to break down the complex issues of illegal state aid and poor governance, using relevant hashtags like #VMO2claim and #Telefonica. X will serve as our primary tool for generating public debate and media interest. You can manage these campaigns and promote key posts through ads.twitter.com to ensure our message reaches influential accounts beyond our organic followers.

For LinkedIn, we will adopt a highly professional tone to target business customers, suppliers, and competitors of VMO2 who may have suffered direct commercial harm. Our content will be in the form of articles and detailed posts on the COCOO company page, outlining the risks of tortious interference and the distortion of fair competition in the UK market. We will use LinkedIn’s powerful ad targeting to reach decision-makers at specific companies and within relevant industries who may have a strong claim or can provide valuable information for our case. You can start creating these targeted campaigns at linkedin.com/ad/accounts, selecting objectives like “Website Visits” or “Lead Generation” directed at our dedicated campaign page.

By executing this multi-platform strategy, we will create a surrounding narrative that reaches every type of prospective class member, from the individual consumer to the large enterprise, compelling them to join our collective action and seek the redress they are entitled to.

ACTION PLAN

Of course. Having processed all 83 search links in the previous nine batches, I will now provide a more granular synthesis of our findings.

Instead of a simple “next batch” from the original list (which is now complete), I have consolidated the intelligence from all sources into a final, actionable strategic plan. This provides the specific granularity needed to move our campaign into the execution phase, linking each strategic objective to the precise evidence we have unearthed.

 

Final Strategic Action Plan & Evidentiary Matrix

 

To: COCOO Leadership

From: In-House Solicitor

Date: 24 June 2025

Subject: Granular Action Plan based on Full Intelligence Review

Our investigation has confirmed that we have two powerful, inter-related cases: one against the Mediaset/Atresmedia duopoly for long-term market abuse and regulatory failure, and one against Telefónica for state-influenced governance and competition distortions.

The following is a granular plan detailing the key evidence for each case and the specific actions we must now take.

 

Part 1: The Case Against the Mediaset/Atresmedia Duopoly

 

Objective: To force the Spanish regulator (CNMC) to reverse its decision and open a new investigation into the duopoly’s current conduct, using the original 2010 merger case (C/0230/10) as the legal anchor.

Key Evidence & Source Files:

  1. Proof of the Original Anti-competitive Risk: The CNMC’s own 2010 analysis concluded the Telecinco/Cuatro merger was a competition risk, making the resulting entity’s advertising space “indispensable” without remedies. The remedies, including a 22% audience cap per ad package and a ban on tying, were detailed in the official implementation plan.
  2.  

    Proof of an 85%+ Market Concentration: The CNMC’s 2019 decision to sanction the duopoly explicitly stated they had a joint market share exceeding 85% and engaged in restrictive practices like demanding minimum investment quotas from advertisers111111111.

     

  3.  

    Proof of Repeated Non-Compliance: Mediaset was sanctioned multiple times for breaching the 2010 merger commitments, including a “very serious” infringement for de facto tying of its channels through its discount policy2222.

     

  4.  

    Proof of Flawed and Failed Enforcement (The “Smoking Gun”): The Audiencia Nacional annulled the CNMC’s 2015 sanction against Mediaset on 10 December 2024, ruling the regulator’s use of anonymized evidence was unlawful and violated Mediaset’s right to defence333333333.

     

Granular Action Plan:

  • Action 1.1 (Legal): Finalise Appeal to the CNMC Council.
    •  

      Tactic: Submit a final supplementary argument to our pending appeal (R/AJ/031/25)4.

       

    • Lead Argument: The 2024 court judgment is a “new fact” that fundamentally alters the case. It proves that the CNMC’s past enforcement failed, the breach was never remedied, and therefore the original competition harm persists. The Directorate’s refusal to investigate is now demonstrably irrational.
    • Required Documentation: Certified copy of the judgment of 10 December 2024 (SENTENCE.V.MEDIASET.BREACH.OF.MERGER.CONDITIONS.pdf).
  • Action 1.2 (Regulatory – EU): Update the European Commission Complaint.
    • Tactic: Formally respond to the EC’s letter of 6 May 2025 (ec gives me 4wks.6may.2.replyorclose.MEDIASET.pdf) where they intended to close our case.
    • Lead Argument: Present the 2024 court judgment as proof of a systemic failure of enforcement at the Member State level, which requires EC intervention. Argue that the CNMC’s inaction has allowed a duopoly to entrench itself, distorting the single market for advertising and content, with direct harm to UK and EU businesses5.

       

    • Required Documentation: The 2024 judgment, plus our analysis from Global Trade Alert and OpenCorporates showing the cross-border corporate structures and trade distortions.

 

Part 2: The Case Against Telefónica & State Intervention

 

Objective: To expose the investment by the Spanish State in Telefónica as an illegal distortion of competition and a threat to corporate governance, with direct, harmful effects on the UK market.

Key Evidence & Source Files:

  1.  

    Proof of State Intervention: The Spanish government, via its holding company SEPI, acquired a 10% stake in Telefónica for ~€2.3 billion, making it the largest shareholder6. This was an explicit reaction to the acquisition of a 9.9% stake by Saudi Arabia’s STC7777.

     

  2. Proof of Politicised Governance: Following the state investment, Telefónica’s leadership was overhauled. This included the appointment of individuals with known political connections to key roles, such as Javier de Paz (former socialist party executive committee member) as President of the media arm Movistar Plus+8888.

     

  3.  

    Proof of a History of Non-Compliance: Telefónica has a long record of being sanctioned by the CNMC for breaching competition rules, including for abusing its dominant position and for repeatedly failing to comply with the commitments from its 2015 acquisition of DTS (Canal+)9999999999999999999999999.

     

  4.  

    Proof of a Direct UK Nexus: Telefónica co-owns Virgin Media O2 (VMO2), a critical UK infrastructure provider, giving it direct influence over one of the largest players in the UK mobile, broadband, and pay-TV markets101010101010101010.

     

Granular Action Plan:

  • Action 2.1 (Legal – EU): File Formal State Aid Complaint.
    • Tactic: Draft and submit a new, dedicated complaint to the EC’s DG COMP.
    • Lead Argument: The SEPI investment fails the “Private Investor in a Market Economy” (PIEM) test. It was not a commercial decision but a political one to assert state control, constituting an illegal and un-notified state subsidy under Article 107 TFEU11111111.

       

    • Required Documentation: Public announcements from the Spanish government and SEPI, financial analysis contrasting the investment with market expectations.
  • Action 2.2 (Regulatory – UK): Prosecute the CMA Complaint.
    • Tactic: Vigorously follow up on our complaint to the UK CMA (CMA TELEFONICA.txt).
    • Lead Argument: The compromised governance of Telefónica presents a direct threat to UK consumers and competition through its control of VMO2. The CMA must investigate this under the “effects doctrine” and its statutory duty to protect UK markets12121212.

       

    • Required Documentation: Our filings to the CMA (CMA TELEFONICA.txt) and evidence of VMO2’s market position in the UK.
  • Action 2.3 (Political – UK): Brief the UK Investment Security Unit.
    • Tactic: Prepare and submit a confidential briefing to the UK Cabinet Office.
    •  

      Lead Argument: The influence of a foreign state (Spain) over a key UK critical national infrastructure provider (VMO2) constitutes a potential national security risk under the National Security and Investment Act 202113131313.

       

    • Required Documentation: Analysis of Telefónica’s governance changes and the structure of the VMO2 joint venture.

 

Part 3: The Monetization Strategy

 

Objective: To convert our legal and investigative work into a tangible financial asset, ensuring the long-term sustainability of COCOO and securing compensation for victims.

Key Evidence & Source Files:

  1.  

    Proof of an Active Market for Legal Claims: Our research identified a sophisticated market of specialist firms that purchase legal assets, distinct from traditional litigation funders14141414.

     

  2.  

    Identification of Potential Buyers: The report HOW 2 SELL MY LITIGATION... explicitly names key firms like Fortress Investment Group, Harbour Litigation Funding, and Certum Group as potential purchasers of claims151515151515151515.

     

  3. Identification of Claimant Classes: Our investigation has identified multiple distinct groups of victims (our “FOC DAM” strategy), including:
    • VMO2 and Movistar consumers (overcharging/poor service).
    • Telefónica’s telecom competitors in Spain and the UK (abusive practices).
    • UK MVNOs using the O2 network (margin squeeze).
    • Advertisers in Spain (forced bundling, anti-competitive pricing).

Granular Action Plan:

  • Action 3.1 (Commercial): Prepare Investment Memorandum.
    • Tactic: Draft a professional, confidential pitch deck for the litigation funding market.
    • Content: The memo will detail the theories of harm, the strong evidence base, the defined claimant classes, preliminary damages models, and our legal team’s expertise.
    • Required Documentation: This will be a synthesis of our entire dossier, presented as a compelling business case.
  • Action 3.2 (Marketing): Launch Public Compensation Campaign.
    • Tactic: Roll out the “Compensación a los afectados” campaign website and social media assets.
    • Timing: The launch must be held until a key “Political Time Window” (PTW), such as the public announcement of an official investigation by the CMA or CNMC, to ensure maximum impact and media coverage.
    • Required Documentation: All draft campaign materials from the file MINISTERIOS TELEFONICA 12 ABRIL.txt.