GEMINI’S PROPOSED SEARCHLINKS
Platform: Google Scholar (scholar.google.com)
Our strategic objective for this platform is to uncover further academic and scientific evidence that substantiates our core legal and economic arguments. This moves beyond legal precedent to find empirical support. The protocol is to conduct a series of advanced searches for scholarly articles and working papers published between 2019 and the present. Search queries will include specific phrases such as "airline competition" AND "state aid" AND "EU", "corporate governance" AND "conflict of interest" AND "Spain", and "regression discontinuity" AND "antitrust". For each relevant paper found, our team will analyse its methodology and conclusions. The goal is to find peer-reviewed research that independently confirms that state aid distorts airline markets, that weak corporate governance is linked to misuse of public funds, or that provides further examples of our “Midnight Mergers” thesis. Such academic work provides a powerful, objective foundation for the expert reports we will commission for any legal action.
Platform: Tesoro Público – Spanish Treasury (tesoro.es)
The Spanish Treasury is the ultimate source of the public funds used in the bailout, making its records a primary financial source. The strategic objective is to understand the complete financial context in which the FASEE loan was made. The protocol is to review all publications, reports, and statistical releases from the Treasury for the period 2020-2021. Specifically, our researchers will analyse reports on government debt issuance to determine the state’s cost of capital at the time. They will also search for any strategic papers on public debt management or financial stability. The goal is to determine the precise financial terms under which the Spanish State was borrowing. This data will allow our financial experts to calculate the effective subsidy provided to Air Europa by comparing the interest rate on its FASEE loans to the government’s own borrowing costs, thereby quantifying a specific component of the illegal state aid.
Platform: Spanish Constitutional Court Jurisprudence (tribunalconstitucional.es)
This platform provides access to the highest level of legal precedent in Spain. Our strategy is to find constitutional-level judgments that could render the entire legal basis for the FASEE fund illegitimate. The granular protocol is to search the court’s jurisprudence database for any decisions related to the limits of executive power, particularly concerning the use of Royal Decree-Laws (Real Decreto-ley)—the instrument used to create FASEE. We will search for keywords like "Real Decreto-ley", "límites" (limits), "competencia desleal" (unfair competition), and "derechos fundamentales" (fundamental rights) in an economic context. The goal is to find any precedent where the Constitutional Court has struck down a government decree for overstepping its authority or for violating principles of economic freedom. Such a finding could allow us to argue that the very instrument that created the fund was unconstitutional, a foundational challenge to the entire affair.
Platform: BOE – Legislation Search (boe.es/buscar/legislacion.php)
A fundamental step in any legal case is the forensic analysis of the specific law in question. The strategic objective here is to obtain and dissect the primary legal texts that created and governed the FASEE fund. The granular protocol is to use the official legislative search to locate and download the full, consolidated text of Real Decreto-ley 25/2020, as well as any subsequent ministerial orders (Orden Ministerial) that developed its procedures, such as the order from July 23, 2020. Our legal team will then conduct a line-by-line analysis, focusing on the stated objectives, the specific eligibility criteria, and the mandated procedures for analysis and approval by SEPI and the Council of Ministers. The goal is to compare the strict requirements of the law with the actions taken by the government, identifying every specific point of non-compliance. This forms the basis of our cause of action for breach of statutory duty.
Platform: Portal de la Transparencia – Spanish Transparency Portal (transparencia.gob.es)
This portal is the primary tool for investigating the Spanish central government’s compliance with its own transparency laws. The strategic objective is to find official information about the FASEE fund’s governance and to document any failures to disclose required information. The protocol is to search the portal for all information related to the “Fondo de Apoyo a la Solvencia de Empresas Estratégicas”. We will look for disclosures on the exact composition of its “Consejo Gestor” (Governing Council), the minutes of their meetings, and any reports on the fund’s performance or the status of its loans. The goal is to find what should be there but is not. The absence of such legally required information is, in itself, evidence of a breach of transparency law and supports our broader narrative of systemic opacity and a deliberate effort to shield the bailout decision from public scrutiny.
Platform: EUROCONTROL (eurocontrol.int)
EUROCONTROL is the key source for objective, pan-European air traffic data. Our strategy is to use their data to independently model and verify the competitive landscape of the European airline industry before and after the bailout. The protocol is for our data analysts to access EUROCONTROL’s publications and statistical databases. We will search for market intelligence reports, traffic analysis, and route-level data for the period 2019-2023. We will focus on traffic flows on routes where Air Europa was a significant competitor, both within Spain and on key trunk routes to other European hubs. The goal is to use this highly credible, independent data to demonstrate the market shares of all players and to model how Air Europa’s post-bailout capacity and traffic deviated from what would be expected under normal market conditions. This provides objective, quantitative evidence of the market distortion.
Platform: IATA – International Air Transport Association (iata.org)
IATA is the voice of the global airline industry. Our strategic objective is to find statements and analysis from the industry itself that are critical of state aid. The protocol is to search the “Publications” and “Press Room” sections of the IATA website for all documents and releases from 2020-2021 related to government aid and COVID-19. We will use search terms like “state aid,” “government support,” “level playing field,” and “competition.” The goal is to find any reports or statements from IATA that warn of the dangers of uncoordinated state bailouts, their potential to distort competition, and the need for aid to be distributed fairly and transparently. Using the industry’s own trade body’s words to critique the specific actions of the Spanish government would be an extremely powerful and credible line of argument.
Platform: EC DG ECFIN Publications (ec.europa.eu)
The objective here is to use the European Commission’s own economic analysis to challenge its legal decisions. The granular protocol is to search the publications database of the Directorate-General for Economic and Financial Affairs for all “European Economic Forecast” reports and any “Discussion Papers” or “Occasional Papers” published between 2020 and 2022 that analyse state aid. We will look for the Commission’s own economic modeling on the impact of these interventions, the criteria for success, and the estimated risks of market distortion. The goal is to find any disconnect between the ECFIN’s cautious economic analysis and DG COMP’s permissive legal approval of the Air Europa bailout. Highlighting such an internal contradiction would be a powerful way to argue that the approval decision was not based on sound economic principles but was driven by other factors.
Platform: OECD (oecd.org)
The OECD sets the international “gold standard” for good governance. Our strategy is to use their standards as a benchmark against which to judge the conduct of the Spanish government. The protocol is to search the OECD’s publications library for two key sets of documents: their “Guidelines on Corporate Governance of State-Owned Enterprises” and any country-specific reports on Spain related to the “Anti-Bribery Convention”. We will extract the specific principles related to transparency, conflicts of interest, and the need for state-owned entities to operate with commercial discipline. The goal is to frame the actions of SEPI and the Spanish government not just as a breach of Spanish law, but as a violation of internationally recognized best practices for good governance, which adds significant weight and reputational pressure to our claims.
Platform: Fitch Ratings (fitchratings.com)
Our strategy with a major credit rating agency like Fitch is to find an independent, financially rigorous, third-party assessment of Air Europa’s creditworthiness before the pandemic. The protocol is to search their archives for any rating reports, industry commentary, or credit analysis on “Air Europa” or “Globalia” published in 2018 and 2019. The objective is to find a professional credit assessment of the company. A report from Fitch that assigned a speculative-grade (“junk”) rating to the company or highlighted significant concerns about its high leverage, weak cash flow, or unsustainable business model prior to 2020 would be an explosive piece of evidence. It would serve as definitive proof from an impartial and highly respected financial authority that the company was indeed “in crisis,” making the subsequent state bailout a clear violation of the eligibility rules.
SEARCHLINKS
Platform: OEPM – Spanish Patent and Trademark Office (consultas.oepm.es)
Our strategic objective for the Spanish Patent andTrademark Office platform is to complete our due diligence on the intangible assets of the corporate entities involved. The protocol is to use the platform’s advanced search capabilities for both trademarks (marcas y nombres comerciales) and patents (invenciones). Our researchers will conduct separate searches for “Globalia Corporación Empresarial, S.A.” and “Air Europa Líneas Aéreas, S.A.U.” in the “Titular” (Holder) field. For each asset found, we will download the full record, noting its status, registration date, and the specific goods or services it covers. The goal is to build a verified, jurisdiction-specific schedule of intellectual property. This information is vital for constructing a complete valuation of the company, which allows us to challenge the proportionality of the state aid provided and to counter any arguments that the bailout was necessary to preserve unique, valuable intangible assets.
Platform: Publicador Concursal – Spanish Insolvency Publication Portal (publicadorconcursal.es)
This platform is a primary target in our search for a “smoking gun” document. The strategic objective is to find official evidence that Air Europa or its parent group were in financial distress prior to the pandemic. The protocol requires a meticulous search of all insolvency notices (resoluciones concursales). Researchers will search for the company names “Air Europa Líneas Aéreas, S.A.U.” and “Globalia Corporación Empresarial, S.A.”, as well as their main subsidiaries. The search will cover all notices published, with a specific focus on the period from January 2019 to March 2020. Finding a declaración de concurso (declaration of insolvency) or even a preconcurso notice from this period would be irrefutable proof that the company was an “empresa en crisis” before the COVID-19 eligibility cut-off date, rendering the entire FASEE bailout illegal.
Platform: BOE – Spanish Official State Gazette, Insolvency Section (boe.es/buscar/concursos.php)
The BOE is the ultimate official journal of record for the Spanish State, and our use of it is to cross-validate and supplement our search of the Publicador Concursal. The granular protocol is to use the BOE’s specific insolvency search function to query for the same company names: “Air Europa” and “Globalia”. We will search for all declaraciones de concurso across all historical records available on the platform. The objective is to ensure absolute completeness in our search for insolvency proceedings. Given the official and permanent nature of the BOE, any evidence found here is legally unimpeachable and would serve as definitive proof to support our primary cause of action that the bailout was granted to an ineligible entity.
Platform: Plataforma de Contratación del Sector Público (contrataciondelestado.es)
This is the central Spanish public procurement platform, which we will use to investigate deeper links between the corporate entities and the Spanish State. The protocol is twofold. First, our researchers will search the database of awarded contracts (adjudicaciones) to see if “Globalia” or “Air Europa” have been the recipients of other public contracts, which could reveal a broader pattern of reliance on or favouritism from the state. Second, we will execute our “Dominating Public Tenders” strategy by searching for past contracts awarded by the Ministry of Transport and the Ministry of Finance for legal and economic consultancy. The goal here is to identify the government’s preferred suppliers. This intelligence allows us to craft a highly targeted Unsolicited Proposal (USP), positioning COCOO as a uniquely qualified expert to advise the Spanish government on implementing anti-corruption and conflict-of-interest frameworks to prevent future debacles.
Platform: Sistema Nacional de Publicidad de Subvenciones (infosubvenciones.es)
This national subsidies database is critical for understanding the full extent of state support received by Air Europa. The protocol is to search the database for “Air Europa” and “Globalia” as beneficiaries (beneficiario). Our team will download the specific record for the €475 million FASEE bailout to have the official data. More importantly, they will download the records for every other subsidy, grant, or loan received by these companies from any public administration in Spain. The goal is to build a complete financial history of all state support. This allows us to argue that the FASEE rescue was not an isolated event to save a healthy company from a once-in-a-generation crisis, but rather the culmination of a pattern of state dependency, further weakening the justification for the enormous bailout.
Platform: Colegio de Registradores de España (registradores.org)
This is the main portal for the Spanish Registrars. It serves as our official channel for obtaining legally certified documents. The granular protocol is for our Spanish legal counsel to use this portal to formally request certificaciones registrales (official registry certifications) for “Globalia Corporación Empresarial, S.A.” and “Air Europa Holding, S.L.U.” from the Registro Mercantil Central. The objective is to obtain legally admissible evidence of the companies’ directorship histories, bylaws, and share capital structure. These official documents are non-negotiable and will form part of the core evidence bundle in any future court proceedings, moving beyond data gathered from secondary sources.
Platform: Registradores.org – Statistical Portal
This statistical portal provides macroeconomic context for our claims. The protocol is for our analysts to extract time-series data on corporate insolvencies (concursos de acreedores) and company dissolutions (disoluciones) for the Spanish “Transport” and “Tourism & Hospitality” sectors. They will focus on the period from 2018 to 2022. The goal is to demonstrate that financial distress was a pre-existing condition in the sector before the pandemic hit. Showing a rising trend of insolvencies in 2019 would powerfully support our argument that Air Europa’s difficulties were not unique and that the justification of its “strategic” nature was a pretext to favour a specific, well-connected company over its struggling competitors.
Platform: Banco de España – RSS Feeds (app.bde.es/rss_www)
This platform allows us to monitor the real-time analysis of the Spanish central bank. The protocol is to subscribe our intelligence feed to the “Publicaciones” (Publications) and “Notas de prensa” (Press Releases) feeds from the Banco de España. Our team will review all publications for any mention of the airline industry, corporate indebtedness, or the economic effects of state guarantee schemes like the FASEE. The objective is to capture any independent analysis from Spain’s most credible economic institution that could corroborate our arguments. A Bank of Spain working paper that questions the efficiency or highlights the moral hazard of the FASEE program would be an exceptionally powerful piece of evidence.
Platform: EU Trade Relationships Portal (policy.trade.ec.europa.eu/eu-trade-relationships-country-and-region)
This European Commission portal will be used to forensically examine the “strategic importance” justification for the bailout. The granular protocol is to navigate to the pages for the specific Latin American countries where Air Europa’s route network is strongest. Our team will review the EU’s stated trade objectives, key economic data, and any ongoing trade dialogues for these specific countries. The goal is to critically assess whether preserving Air Europa’s routes was genuinely vital to the EU’s strategic trade interests or if this was an exaggerated claim. This analysis allows us to dismantle a key pillar of the government’s justification for the bailout, framing it instead as a decision that served narrow corporate interests under the guise of strategic national importance.
Platform: PACER – Public Access to US Court Electronic Records (pacer.gov)
The strategic objective for using the PACER system is to uncover any litigation within the US federal court system that could provide admissions or evidence relevant to our case. The protocol is to use the PACER Case Locator to conduct nationwide searches for all case types, including civil, bankruptcy, and appellate. Our researchers will execute searches using the party names “Air Europa,” “Globalia Corporación Empresarial,” “International Airlines Group,” and major US competitor airlines. The granular task for any relevant case found is to download and scrutinise key filings: initial complaints, motions, sworn declarations, expert witness reports, and deposition transcripts. The goal is to locate any statements made under oath or arguments made in court by these companies concerning their financial health, the competitive landscape of the transatlantic market, or the specific impact of EU state aid. Such documents can be used as powerful evidence or as admissions against interest.
Platform: USAspending.gov
Our use of this platform is to conduct due diligence on any financial relationship between the key corporate entities in our case and the United States government. The protocol is to use the advanced search to query all federal award data. Researchers will search for “Air Europa,” “Globalia,” and “International Airlines Group” in the “Recipient” field. The search will span all award types, including contracts, grants, and loans. The objective is to identify any such financial ties. While not a primary line of inquiry, discovering that one of the involved companies is a significant US government contractor could add an important layer of political and economic context to our understanding of the case’s international dimensions and the US government’s potential interest in the matter.
Platform: WIPO Global Brand Database (wipo.int/branddb/en)
This platform is a tool for comprehensive due diligence on the intangible assets of the corporate targets. The granular protocol is to use the database to conduct an exhaustive search for all trademarks owned by “Globalia Corporación Empresarial, S.A.” and its subsidiary “Air Europa Líneas Aéreas, S.A.U.”. The search will be executed using the “Holder” name field and will encompass all international jurisdictions available through the portal. For each trademark found, we will document its status, the classes of goods and services it covers, and its registration history. The goal is to build a complete intellectual property profile, which is essential for fully understanding the value and strategic positioning of the Air Europa brand that the bailout was intended to preserve.
Platform: OpenOwnership Register (openownership.org/en/register)
The objective with this platform is to search for publicly declared beneficial ownership data that may not be available elsewhere, directly supporting our investigation into potential conflicts of interest. The protocol is to search the global register for the entities “Globalia Corporación Empresarial” and “Air Europa”. Given that this register aggregates data from various national sources that have made their data public and interoperable, it offers a chance to find structured information on the ultimate beneficial owners. The primary goal is to identify the natural persons who have been declared as exercising ultimate control. Any discrepancy between the information found here and the legal ownership data from official Spanish registries would be a significant red flag and a powerful piece of evidence suggesting an attempt to obscure the true ownership structure.
Platform: Infocif – Spanish Company Information (infocif.es)
This commercial platform will be used to obtain financial data of a granularity that exceeds what is available on the free public registers. The protocol is to purchase the most comprehensive financial and corporate report available for “Globalia Corporación Empresarial, S.A.” and for “Air Europa Holding, S.L.U.”. The granular task is to meticulously analyse the financial accounts for the fiscal years 2018 and 2019. We will search for key indicators of financial distress, such as negative equity, high debt-to-equity ratios, and sustained operational losses, which would substantiate our central finding that Air Europa was a “company in crisis” prior to the pandemic. We will also use the corporate linkage tools to visualise the full group structure. This detailed financial analysis is the cornerstone of our argument against the legality of the bailout.
Platform: Spanish Ministry of Finance – Declarations of High-Ranking Officials (hacienda.gob.es)
This official government portal is a primary target for direct evidence relating to our conflict of interest allegations. The protocol is for our Spanish legal team to navigate the site to find and download the publicly available declarations of assets and interests for President Pedro Sánchez and former Minister José Luis Ábalos for the years 2019, 2020, and 2021. The granular objective is to analyse what was, and was not, declared. We will compare the official filings with our own evidence of the meetings and professional relationships between the President’s wife and Globalia. An omission of such a relevant connection would itself be a significant finding and could constitute a breach of Spanish transparency and ethics laws, providing a clear and powerful piece of evidence to support our cause of action.
Platform: Spanish Congress of Deputies (congresodiputados.es)
The website of the Spanish Parliament is a repository of official government statements and positions. The protocol is to use the site’s publication and initiative search functions to find all parliamentary records related to the Air Europa case. Our researchers will search for the keywords “Air Europa,” “FASEE,” “SEPI,” and “Koldo” from 2020 to the present. The granular task is to retrieve the full transcripts of any oral questions, committee appearances, and formal written questions from MPs, along with the corresponding official answers from the government. The goal is to find any instances where the government has made misleading, evasive, or contradictory statements to Parliament. Such official records provide irrefutable evidence of a lack of transparency and a potential cover-up, which powerfully supports our cause of action for the “abnormal functioning of public services”.
Platform: CNMV – Spanish National Securities Market Commission (cnmv.es)
The CNMV is the Spanish equivalent of the UK’s FCA or US’s SEC, and its records are a primary source of evidence regarding IAG’s disclosures. The protocol is to search the CNMV’s database of “Hechos Relevantes” (Material Events) for all filings made by International Airlines Group. The search will cover the period from the initial merger announcement in November 2019 through to its eventual collapse. Our team will download and compare the text of the Spanish filings with the equivalent RNS filings made to the London Stock Exchange. The granular objective is to identify any differences in wording, detail, or timing between the disclosures made to the Spanish and UK markets. Any material discrepancy could be significant and may reveal a tailored communication strategy intended to manage the perceptions of different sets of investors and regulators.
Platform: CNMC – Spanish National Markets and Competition Commission (cnmc.es)
The CNMC website is a source of official evidence from Spain’s own competition authority. The protocol is to locate and download the complete public file related to the CNMC’s analysis of the proposed IAG and Air Europa merger. This will include the initial notification, any market analysis reports conducted by the CNMC’s staff, and the formal decision documents, including the decision to refer the case to the European Commission. The goal is to extract the Spanish regulator’s own stated concerns regarding the “significant lessening of competition” that the merger would cause. These official findings from the CNMC would serve as highly credible, independent evidence that powerfully corroborates our own analysis of the anti-competitive harm that the bailout was intended to facilitate.
Platform: Catalan Transparency Portal (transparencia.gencat.cat)
This regional portal is a source for ancillary evidence and political pressure. The granular protocol is to search the portal for any official positions, reports, or statements made by the Generalitat de Catalunya or its relevant departments concerning the Air Europa bailout. Given the importance of Barcelona’s El Prat airport to the Catalan economy, we will search for terms like “Air Europa,” “competencia aérea” (airline competition), and “aeropuerto del Prat.” The goal is to find any official expression of concern from a powerful regional government regarding the bailout’s impact on competition. Such a finding would provide a valuable third-party critique from another public body within Spain, demonstrating that concerns about the deal were not limited to competitors but were shared by other governmental actors.
Platform: AJ Bell Investment Trust Screener (ajbell.co.uk/markets/investment-trusts)
Our strategic objective for this platform is to broaden our “smart money” analysis from individual shareholders to the investment trusts that hold significant positions in the aviation sector. The protocol requires our analysts to use the screener to identify all UK-listed investment trusts that either specify a focus on the “Travel & Leisure” sector or which list International Airlines Group (IAG) as a top ten holding. For each trust identified, the team will acquire its latest annual report and portfolio factsheet. The granular task is to then text-search the “Manager’s Commentary” section for keywords such as “competition,” “consolidation,” “state aid,” and “IAG.” The goal is to extract commentary from professional fund managers that validates our own analysis of the market dynamics. A fund manager’s independent statement questioning the long-term competitive health of the European airline market due to state intervention would be a highly credible piece of third-party evidence to support our case.
Platform: UK Government Publications (gov.uk/government/publications)
This platform will be used to conduct a comprehensive sweep for any relevant UK government documents that exist outside of formal regulatory case files. The protocol is to use the advanced search function to query the entire GOV.UK publications database. Our researchers will execute searches for the exact phrases “Air Europa” and “FASEE,” filtering by date to cover 2019 to 2023. They will also run broader searches for documents containing the keywords “airline,” “competition,” and “state aid,” filtering by organisation to include the Treasury (HMT), the Department for Transport, and the Cabinet Office. The objective is to uncover any hidden policy papers, internal guidance, impact assessments, or minutes from cross-departmental committees that discuss the Spanish bailouts or the IAG merger. Finding such a document could provide a “smoking gun” regarding the UK government’s internal assessment of the situation, which may differ from its public-facing neutrality.
Platform: UK Government Organisations (gov.uk/government/organisations)
This platform serves as a directory for mapping the UK regulatory state. The strategy is to ensure we have not overlooked any public body with a potential interest in or influence over our case. The protocol is for our team to review the directory and identify not only the primary actors like the CMA and DfT, but also secondary bodies. This could include, for example, the UK’s Civil Aviation Authority (CAA) regarding route licensing, or specific all-party parliamentary groups (APPGs) focused on aviation or Spain. The goal is to build a complete map of the UK’s institutional landscape. For each identified body, we can then formulate a targeted Freedom of Information request or search for their publications, ensuring no stone is left unturned in our pursuit of relevant information.
Platform: London Stock Exchange Price Explorer (londonstockexchange.com/live-markets/market-data-dashboard/price-explorer)
This platform will be used to conduct a targeted event study on IAG’s stock performance, providing quantitative evidence of the market’s perception of the bailout. The granular protocol requires our financial analysts to use this tool to download the daily historical share price and trading volume data for International Airlines Group (IAG) for the period covering November 2019 to August 2024. They will then plot this data against the specific dates of key events: the original IAG-Air Europa merger announcement, the announcement of the Spanish FASEE bailout, the announcement of the renegotiated merger price post-bailout, and the eventual collapse of the deal. The strategic goal is to isolate the market’s reaction to the bailout itself. A statistically significant abnormal positive return for IAG’s stock immediately following the announcement of the rescue of its acquisition target would be powerful evidence for our argument that the primary beneficiary of the public funds was perceived to be IAG’s shareholders, not the public interest.
Platform: Bidstats.uk
This UK public procurement database will be used to conduct a forensic analysis of the government’s existing supplier relationships, informing our own public contract acquisition strategy. The protocol is to use the platform to search for all historical contract awards from our key target entities: the Competition and Markets Authority and the Department for Transport. We will filter for contracts related to economic consultancy, forensic analysis, and legal advisory services. For each major incumbent supplier identified, we will then build a dossier using our other intelligence tools. The objective is to understand who the government trusts, what they pay for these services, and, critically, what the weaknesses of these incumbent firms are. This intelligence is invaluable for crafting our own Unsolicited Proposals, which can be tailored to offer a solution that directly addresses a gap or weakness in the service provided by the current supplier.
Platform: WTO Dispute Settlement (wto.org/english/tratop_e/dispu_e/dispu_e.htm)
Our strategic engagement with the WTO’s dispute database is to find legal precedent that can be used to construct a potential state-level trade dispute. The granular protocol is to search the database of dispute cases not by keyword, but by filtering for all cases where the respondent was the “European Union” and the subject involved “subsidies” or “services”. Our legal team will analyse the legal arguments, panel reports, and appellate body decisions in these cases. The objective is to understand the legal tests and evidentiary standards the WTO applies to disputes over illegal subsidies in non-goods sectors. This research provides a foundational legal playbook for our “USP-to-WTO” strategy, enabling us to frame any potential trade-related harm caused by the Air Europa bailout in a manner consistent with successful past WTO litigation.
Platform: US Office of Government Ethics (oge.gov)
This platform will be used as a source of comparative intelligence to establish a “gold standard” for ethical conduct. The strategy is to benchmark the alleged actions of the Spanish President against the stringent rules governing the US Executive Branch. The protocol is for our team to review and synthesise the OGE’s published guidance documents, legal advisories, and regulations concerning conflicts of interest, particularly the rules on recusal and the financial interests of spouses. The goal is to create a clear summary of what constitutes best practice in a major Western democracy. This can then be deployed in our communications and legal arguments to starkly contrast these clear standards with the apparent ethical and legal failures in the Air Europa case, thereby amplifying the perceived gravity of the infringements.
Platform: US Congress (congress.gov)
The official US legislative portal will be used to find evidence of international concern over the EU’s state aid policies in the aviation sector. The protocol is to use the platform’s advanced search to find any committee hearings, reports, or legislative debates from 2020-2022. The search query will combine keywords such as “airline,” “subsidies,” and “European Union” within the text of congressional records. We will focus on the output of the House Committee on Transportation and Infrastructure and the Senate Committee on Commerce. The goal is to find any instances where US lawmakers or officials formally expressed concern that the EU’s airline bailouts, including the one for Air Europa, were creating an unlevel playing field and harming the interests of US carriers on competitive transatlantic routes. Such a finding would be powerful evidence that the harm was not merely domestic but had international repercussions.
Platform: Espacenet & USPTO Patent Publications (worldwide.espacenet.com & ppubs.uspto.gov)
These global and US patent databases will be used to conduct final, comprehensive due diligence on the corporate entities involved. The protocol is to conduct searches on both platforms using the “Applicant” or “Assignee” fields for “Air Europa Líneas Aéreas, S.A.U.” and its parent “Globalia Corporación Empresarial, S.A.”. The search should cover all active patents and recent applications. The objective of this granular check is to ensure that no significant intangible assets, such as proprietary booking technology or logistics software, have been overlooked in our analysis of the company’s value and strategic assets. While not expected to be central to our case, confirming the intellectual property portfolio of the entities demonstrates the thoroughness of our investigation and closes off any potential surprises, reinforcing our position as the most knowledgeable party in any negotiation.
Platform: UK Register of Consultant Lobbyists (gov.uk/government/publications/register-of-consultant-lobbyists)
The strategic objective here is to uncover any covert or third-party lobbying efforts in the UK that were intended to influence the government or regulators regarding the IAG-Air Europa merger. The protocol is to systematically search the quarterly-published register, focusing on the period from 2019 through 2022. Our researchers will not only search the client lists for “International Airlines Group” or “IAG,” but will also search for major aviation-focused public affairs firms to review their entire client list for that period. The goal is to identify any indirect lobbying efforts. For instance, discovering that a financial institution with a vested interest in the merger’s success hired a lobbyist to discuss “aviation sector policy” with Treasury officials during the critical timeframe would provide a new and compelling line of inquiry for our investigation into the undue influence surrounding the deal.
Platform: Scottish Parliament Lobbying Register (lobbying.scot)
Our engagement with this platform is to ensure the comprehensive scope of our investigation into political influence. The granular protocol is to replicate the search strategy used for the main UK register, but tailored to the Scottish context. Researchers will search the register for any regulated lobbying of Members of the Scottish Parliament (MSPs) or the Scottish Government where the subject was aviation or tourism, and the client was IAG, British Airways, or a related entity. Given that major Scottish airports like Glasgow and Edinburgh are key UK hubs, any lobbying on route competition or airport policy would be highly relevant. The goal is to determine if a parallel lobbying effort occurred at the devolved level, which could reveal a more extensive and sophisticated influence campaign than is immediately apparent.
Platform: UK Civil Appeals Case Tracker (casetracker.justice.gov.uk)
This platform is a critical monitoring tool for our “APPEALS (JR2COURT)” strategy. The protocol is to establish a weekly routine for searching the case tracker. We will search not only by case title for the names of major airlines but also by the names of the specialist law firms known to act for them. We will also search for any judicial review applications lodged against the Competition and Markets Authority. The objective is to gain the earliest possible intelligence on any appeals in related competition law cases. If a judgment in a separate case concerning the definition of a “significant lessening of competition” in a network industry is appealed, the outcome of that appeal could create a new legal precedent that directly impacts the arguments we would make in court. Early knowledge of such an appeal is a significant strategic advantage.
Platform: Royal Courts of Justice Cause List (gov.uk/government/publications/royal-courts-of-justice-cause-list)
This is a real-time intelligence tool, not a historical database. The granular protocol is for our UK legal team to perform a daily review of the published cause lists for the Commercial Court and the Competition List within the Business and Property Courts. They will scan for any scheduled hearings, from brief procedural matters to full trials, involving IAG, Ryanair, or other key players in the UK aviation market. The goal is to monitor their active litigation in real time. Knowing that a key competitor is currently engaged in costly and distracting litigation on another front might inform the optimal timing for us to approach them to join our collective action, as they may be more financially and strategically motivated to open a new front with a strong claim.
Platform: Find a Tender Service (find-tender.service.gov.uk)
We will deploy our “Dominating Public Tenders” playbook with this platform. The granular protocol is to move beyond simply looking for future opportunities and to perform a forensic analysis of past awards. Our researchers will use the advanced search to filter for “Awarded” contracts with CPV codes related to “Legal advisory services” and “Economic analysis.” They will focus on contracts awarded by the Department for Transport and the CMA. For each relevant awarded contract, we will identify the winning firm, the contract value, and the names of the individuals listed on the bid. This intelligence will be cross-referenced with our other tools. The goal is to deconstruct what a winning bid looks like to these specific government bodies and to build a profile of the incumbent suppliers. This allows us to craft any future bid or Unsolicited Proposal to directly address the weaknesses or pricing of the current provider, giving us a significant competitive edge.
Platform: LobbyFacts.eu (lobbyfacts.eu)
This platform is essential for mapping the financial and political power brought to bear on EU institutions. The granular protocol is to conduct a detailed analysis of the lobbying declarations of all major aviation players. We will search for “International Airlines Group (IAG),” “Lufthansa Group,” and “Air France-KLM.” We will extract and compile data on their declared annual lobbying budgets, the number of accredited lobbyists, and crucially, the number of high-level meetings held with European Commissioners and their cabinet members or Directors-General at DG COMP and DG MOVE. The objective is to create a quantitative and visual “map of influence,” which we can use in our public communications to illustrate the intense lobbying pressure surrounding state aid decisions. This evidence helps us argue that the approval was not a simple technical matter but occurred in an environment of immense political pressure.
Platform: EC Press Corner (ec.europa.eu/commission/presscorner/home/en)
This archive of official communications is a source of direct evidence. The protocol is to conduct a meticulous search of all press releases, speeches, and “read-outs” of College of Commissioners meetings from 2020 and 2021. Our search terms will include exact phrases like “Air Europa,” “FASEE,” “Temporary Framework,” and “strategic interest.” The objective is to capture the precise public justifications offered by the Commission at the time of the bailout’s approval. These official statements will be treated as a benchmark. We will then compare this public narrative line-by-line against the facts uncovered in our investigation. Any discrepancy, misleading statement, or significant omission will be catalogued and used as evidence to challenge the credibility and legality of the Commission’s decision-making process.
Platform: EU Online Dispute Resolution (ec.europa.eu/consumers/odr)
While this platform is designed for individual consumer-to-business disputes, our strategy is to use it as a tool for coordinated, high-volume action. The protocol is to first identify a common, legally sound complaint affecting a large number of consumers—for example, a specific pattern of flight cancellations or a refusal to issue refunds by one of the involved airlines. We will then create a simplified guide for affected consumers on how to use the ODR platform to file their complaint. Through a targeted media campaign, we will encourage a mass filing of these individual disputes. The goal is not to win each case, but to generate thousands of official complaints within the EU’s own system. This action creates a significant administrative burden for the target airline and produces an undeniable statistical record of consumer harm, which we can then cite as evidence in our broader public interest case.
Platform: Your Europe – Tenders (europa.eu/youreurope/business/finance-funding/getting-funding/tenders/index_en.htm)
This platform is a preparatory resource. The strategic objective is to ensure COCOO achieves full operational readiness for EU procurement. The protocol requires our administrative team to conduct a full review of the guidance provided here. They will familiarise themselves with the entire lifecycle of an EU tender, from finding opportunities on the TED (Tenders Electronic Daily) portal to understanding the rules on consortia and subcontracting. They will be tasked with preparing a draft version of the European Single Procurement Document (ESPD) for COCOO. The goal is to eliminate any administrative hurdles in advance, so that when a relevant contract opportunity is identified, we can assemble and submit a high-quality, fully compliant bid at speed.
Platform: AJ Bell Share Screener (ajbell.co.uk/market-research/screener/shares)
This financial analysis tool will be used to execute our “smart money” intelligence strategy. The granular protocol is to use the screener to analyse the shareholder base of IAG and its UK-listed competitors like easyJet. We will filter the results to identify the “Major Shareholders,” focusing on large institutional investors such as pension funds, sovereign wealth funds, and asset managers known for their focus on Environmental, Social, and Governance (ESG) principles. We will then track the history of their holdings. The goal is to identify which institutions were most heavily invested in IAG during the merger and bailout period. This information is a point of leverage. An ESG-focused pension fund, for example, may be highly sensitive to the reputational damage of being associated with a transaction now tainted by credible allegations of corruption and conflict of interest. They could become a powerful and influential advocate for a swift and fair settlement.
Platform: EUR-Lex (eur-lex.europa.eu)
Our strategic objective for EUR-Lex, the primary gateway to all European Union law, is to deconstruct the legislative and policy history of the regulations governing state aid during the pandemic. This allows us to argue not just against the letter of the law, but against its intended spirit. The protocol is to use the “Advanced search” function to locate the COVID-19 State Aid Temporary Framework. Crucially, we will not stop at the final legal text. We will trace its entire legislative history by retrieving the associated preparatory documents. This includes the original “Proposal” from the Commission (COM documents), any “Opinions” from the European Economic and Social Committee, and records of debates. The goal is to find language within these preliminary documents that explicitly warns of the risks of misuse, the need for strict verification of a company’s pre-crisis financial health, and the potential for such aid to create severe anti-competitive distortions. Locating this evidence of legislative intent will be invaluable in demonstrating that the Spanish government and potentially the Commission acted with reckless disregard for the known dangers the framework was designed to prevent.
Platform: UK Business and Property Courts (gov.uk/government/organisations/business-and-property-courts)
This government portal is not a search database for evidence, but a source of critical procedural intelligence. The strategic objective is to ensure that should we initiate any related claim in the United Kingdom, our legal team operates with complete procedural mastery from the outset. The protocol requires our UK legal counsel to meticulously review the published Court Guides and Practice Directions for the relevant specialist courts, particularly the Competition List and the Financial List. They will study the specific requirements for pre-action conduct, the format of claim forms, and the expectations for case management conferences. The goal is to gain an intimate understanding of the court’s processes and the judiciary’s expectations. This preparation ensures any action we file is procedurally flawless, signals our competence and seriousness to the court and our adversaries, and allows us to navigate the litigation process more efficiently and effectively.
Platform: Companies House Advanced Search (find-and-update.company-information.service.gov.uk/advanced-search)
This advanced search interface for the UK’s company register will be used to execute a highly targeted search to identify potential UK claimants. The protocol is to move beyond simple name searches and employ the specific filters available. Our researchers will first use the “Nature of business (SIC)” filter, inputting the official code for “Scheduled passenger air transport” (51101) to isolate all UK-registered airlines. They will then apply a secondary filter for “Company status” to include only “active” companies. This refined list will then be manually reviewed to identify independent carriers who were in direct competition with the IAG/Air Europa conglomerate on key UK-Spain or UK-Latin America routes. The objective is to produce a high-probability list of corporate victims who suffered direct financial harm. This list is the foundation of our claimant recruitment for any collective action, a cornerstone of our FOC DAM (Find Other Claimants, Monetize Damages) doctrine.
Platform: UK SIC Code Directory (resources.companieshouse.gov.uk/sic/)
This platform is a preparatory tool to ensure the precision of our sectoral analysis. The protocol is to use this official directory to compile a definitive list of Standard Industrial Classification codes for every industry tangential to our case. This goes beyond just airlines (51101) to include “Freight transport by air” (51210), “Travel agency activities” (79110), “Tour operator activities” (79120), and other logistics and tourism-related sectors. The strategic goal is to build a comprehensive map of the affected ecosystem. Using these precise codes in our searches on other platforms like Companies House and Violation Tracker ensures our data is accurate, consistent, and captures all relevant corporate entities, preventing any potential victims or targets from being missed due to incorrect industry classification.
Platform: UK Parliament Petitions (petition.parliament.uk)
This platform will be weaponised as a public and political pressure tool. The strategy is to translate our complex legal findings into a simple, powerful public narrative. Once we have compiled sufficient evidence of harm to UK consumers, such as data suggesting higher fares on holiday routes to Spain due to a lack of competition, our communications team will draft a public petition. The petition will call on the UK Government and Parliament to launch an official inquiry into the impact of the Air Europa bailout on the UK travel market. The petition will be seeded with key stakeholders like consumer rights groups and travel industry associations. The goal is to generate signatures and media coverage. Reaching the 10,000-signature threshold mandates an official government response, while reaching 100,000 means it will be considered for debate. This creates a public-facing political crisis that runs parallel to our legal manoeuvres, significantly increasing the pressure on all parties to engage with us and seek a resolution.
Platform: Register of Members’ Financial Interests (parliament.uk)
This official parliamentary register is a source for investigating potential political conflicts of interest within the UK. The protocol is to conduct a systematic review of the register for the period covering the announcement of the IAG acquisition attempt and the Air Europa bailout. Researchers will search for any Member of Parliament who has declared shareholdings in IAG, other major airlines, or travel conglomerates. They will also search for any declared gifts, benefits, or paid advisory roles from such companies. The search will focus particularly on MPs who were members of the Transport Select Committee or the Business, Energy and Industrial Strategy Select Committee at the time. The objective is to uncover any undisclosed political leverage or conflicts that may have influenced the UK government’s or the CMA’s posture towards the merger and the associated state aid issues.
Platform: TheyWorkForYou Interests Search (theyworkforyou.com/interests/)
This platform provides a more efficient way to execute the protocol for the official Register of Interests. Its keyword search functionality is a significant advantage. The granular protocol is to run searches for specific corporate keywords such as “International Airlines Group,” “IAG,” “British Airways,” “Ryanair,” and “Globalia.” We will also search for the names of major aviation-focused public affairs and lobbying firms. The goal is to rapidly identify any declarations that mention these entities, which may not be obvious from a manual review of the official register. This tool allows us to accelerate our due diligence on potential political conflicts of interest within the UK Parliament.
Platform: HUDOC – European Court of Human Rights (hudoc.echr.coe.int)
Our strategy for the ECHR database is to explore novel legal arguments that could dramatically escalate the legal risk for the Spanish state. The protocol is to use the HUDOC advanced search to find cases brought against Spain related to commercial or property disputes. Crucially, we will filter the “Document Collection” to focus on “Communicated Cases,” which are cases deemed admissible and sent to the government for a response. We will search using keywords like “effective remedy,” “fair hearing,” “protection of property,” and “competition.” The objective is to identify any precedent where the ECHR has found that a flawed, opaque, or arbitrary state process has violated a company’s rights under Article 6 (Right to a fair trial) or Article 1 of Protocol 1 (Protection of property). Finding such a case would allow us to argue that the Spanish state’s handling of the Air Europa bailout not only broke administrative and competition law but also violated the fundamental rights of its competitors, opening up a new and formidable legal battlefront.
Platform: EU Have Your Say (ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/have-your-say)
This portal is a strategic tool for policy influence and placing our evidence on the official EU record. The protocol is to have our team monitor the portal weekly for any new policy initiatives, roadmaps, or public consultations concerning state aid, competition law, or the transport sector. When a relevant consultation arises, we will prepare a formal, detailed submission. This submission will use the Air Europa bailout as a primary case study, laying out our evidence of how the existing rules were circumvented and the systemic flaws this exposed. The goal is twofold: we directly contribute to shaping future EU policy to prevent such a situation from happening again, and we officially register our detailed complaints and evidence with the European Commission in a public forum, creating a permanent record that can be referenced in all future correspondence and legal action.
Platform: The UK National Archives (nationalarchives.gov.uk)
The National Archives will be used to find historical government policy documents that can be used to challenge the current government’s actions as inconsistent and unprincipled. The granular search protocol is to use the “Discovery” catalogue to find records from the Treasury, the Cabinet Office, and the Department for Transport from previous eras concerning airline competition. We will search for files relating to the British Airways privatisation, the government’s stance on previous European airline mergers, and policies on state aid to strategic industries. The goal is to uncover historical memos, minutes, and policy papers that establish a baseline for UK government policy. If we can demonstrate that the government’s passivity in the face of the Air Europa bailout contradicts decades of its own established policy of promoting free competition, we can frame their inaction as a politically convenient departure from principle, which is a powerful argument to make in both a court of law and the court of public opinion.
Platform: TRON – EU Trade Defence Instruments (tron.trade.ec.europa.eu)
Our strategic use of the TRON platform is to identify the secondary and tertiary impacts of the market distortion caused by the Air Europa bailout. While not a source for direct evidence of the bailout’s illegality, it can provide a wider picture of competitive harm. The protocol requires our researchers to search the database of trade defence investigations, focusing on cases initiated between 2020 and the present. The search will be filtered by industry sector, using NACE codes relevant to passenger air transport and air cargo. The objective is to identify any anti-subsidy or anti-dumping investigations involving EU airlines. A finding that other EU member states initiated actions against allegedly subsidised non-EU carriers during this period would highlight the hypocrisy and inconsistency of the Commission’s approval of the massive Air Europa aid package. It would serve as powerful contextual evidence that the Commission was applying its rules unevenly, which supports our broader narrative of an arbitrary and politically motivated decision.
Platform: Access2Markets (trade.ec.europa.eu)
The Access2Markets portal will be used to gather economic data that frames the strategic importance of the routes dominated by Air Europa and IAG. The protocol is to use the portal to analyse trade flows and identify reported trade barriers affecting the EU aviation sector, particularly on routes to Latin America. Our researchers will extract data on the value of services trade in aviation and tourism between the EU and key Latin American countries. They will also catalogue any existing complaints or reported barriers faced by EU carriers in those markets. The strategic goal of this search is to build a narrative that the FASEE funds could have been better deployed to address these systemic trade issues rather than being used to rescue a single, allegedly non-viable player. This line of argument is not for a direct legal claim, but is a powerful political and public interest argument we can use in our public communications and as leverage in any mediation.
Platform: EuroVoc (showvoc.op.europa.eu)
This platform is a preparatory tool, essential for ensuring the precision of all our searches across EU databases. It is not a source of evidence itself, but a source of correct terminology. The protocol is for our research team to use EuroVoc to create a definitive glossary for our case. They will look up our key concepts—such as “state aid,” “conflict of interest,” “public procurement,” and “air transport”—and extract the official multilingual thesaurus terms and their corresponding numerical identifiers. Using these official terms in searches on platforms like CURIA and EUR-Lex will bypass the ambiguities of natural language keywords and ensure our searches are exhaustive, capturing all relevant documents regardless of the language they were published in. This is a foundational step for all rigorous EU-level legal and policy research.
Platform: Eurostat (ec.europa.eu/eurostat)
Eurostat is our source for authoritative, quantitative data to prove the market distortion alleged in our findings. The granular protocol involves a detailed extraction of transport statistics. Researchers will navigate to the air transport datasets and compile time-series information from 2018 to the present. We will focus on passenger-kilometres, load factors, and market share data for carriers on specific city-pair routes between Spain and other EU countries, and between Spain and key Latin American destinations. The objective is to compare the post-bailout performance of Air Europa against its direct competitors on a route-by-route basis. By establishing a pre-pandemic baseline, we can statistically model the impact of the €475 million injection, demonstrating how it enabled Air Europa to maintain or grow market share in a way that was detached from normal market forces. This data will be indispensable for quantifying damages.
Platform: Data.gov.uk
The UK’s public data portal will be used to uncover UK-specific impacts and to identify potential UK-based claimants. The protocol is to search for datasets from the Department for Transport and the Civil Aviation Authority. We will use search terms like “airline,” “air passenger,” “competition,” “route analysis,” and “consumer complaints.” We are specifically looking for datasets that detail market concentration on routes between the UK and Spain, or data on passenger fare trends. The strategic goal is to find official UK data that illustrates a tangible negative impact—such as reduced carrier choice or higher fares on key holiday and business routes—following the distortion in the Spanish market. This evidence would be critical for recruiting UK-based consumer groups and business organisations into our collective action, thereby broadening our claimant base as per our FOC DAM doctrine.
Platform: Violation Tracker UK (violationtrackeruk.org)
This platform is key to our strategy of understanding the full context of the major players. As per our CaseLink Doctrine, the protocol is to build a comprehensive “Violation Dossier” on International Airlines Group (IAG) and its subsidiary British Airways. Researchers will use the “Parent Company” search field to ensure all subsidiary violations are captured. We will catalogue every penalty, paying close attention to any infringements related to competition law, consumer protection failings, or environmental regulations. The objective here is not necessarily to use this information in a direct legal claim, but to hold it as strategic intelligence. In any negotiation or mediation with IAG, having a complete, evidence-based picture of their regulatory compliance history provides significant leverage and informs our assessment of their corporate character and potential vulnerabilities.
Platform: Competition Appeal Tribunal (catribunal.org.uk)
The CAT website is a primary source for UK-specific legal precedent in competition law. The granular protocol is to use the advanced case search to find all judgments and ongoing proceedings related to the airline industry. We will search for claimant and defendant names including “International Airlines Group,” “IAG,” “British Airways,” “Ryanair,” and “easyJet.” We will also search for keywords such as “merger,” “state aid,” and “abuse of dominance.” Our researchers will analyse the full text of judgments to understand how the CAT interprets key legal concepts, such as the relevant market definition for airline routes and the standard of proof required for showing competitive harm. This research is vital for assessing the viability of bringing a follow-on damages claim in the UK courts and for tailoring our legal arguments to align with the established jurisprudence of the Tribunal.
Platform: UK Competition and Markets Authority (gov.uk/government/organisations/competition-and-markets-authority)
This is a primary evidence source for the harm caused by the proposed IAG/Air Europa merger, which the bailout was intended to facilitate. The protocol is to locate the CMA’s full case file on the merger review. Our team will download and systematically dissect every public document in the case register, including the initial merger notice, the issues statement identifying the CMA’s preliminary concerns, all submissions from the merging parties and third parties, and the final decision documents. The objective is to extract the CMA’s own detailed analysis and conclusions regarding the “significant lessening of competition” that the merger would have caused on specific UK-Spain and transatlantic routes. The CMA’s own findings are highly credible, independent evidence that validates our core argument of anti-competitive harm. This evidence can be used directly to support our claims.
Platform: DG Competition (competition-policy.ec.europa.eu)
We will execute a more granular search of the EU Commission’s competition portal. The protocol is to move beyond the main decision documents for the Air Europa state aid case (SA.59125). Our researchers will search for and download all “third party submissions” related to this case and the associated merger reviews. These documents often contain detailed economic analyses and arguments from competing airlines, airports, and consumer groups who identified the potential for harm from the outset. We will also search the speeches and press releases archives from 2020-2021 for any statements by the Competition Commissioner or key DG COMP officials that define their policy on airline state aid. The goal is to find evidence of warnings that were ignored or policy statements that contradict the eventual approval decision, which would support a cause of action based on the arbitrary and flawed nature of the Commission’s review.
Platform: BAILII (bailii.org)
This legal database will be used to find binding or persuasive case law from the UK’s senior courts. The search protocol requires the use of advanced Boolean operators to find precedent on our core causes of action. To research the legal consequences of a conflict of interest in a public decision, researchers will use precise queries such as: ("public authority" OR minister OR "decision-maker") AND ("conflict of interest" OR "apparent bias") AND (abstain* OR recuse*). To find precedent on challenges to government aid, the search query will be: ("state aid" OR "public funds" OR grant) AND ("ultra vires" OR "irrationality" OR "procedural impropriety"). The objective is to build a dossier of UK case law that establishes the legal principles of good administration and the non-negotiable duty of public officials to avoid conflicts of interest. This legal foundation is essential for demonstrating the gravity of the infringements we have identified.
Platform: OpenSanctions Advanced Search and Associated Documentation (opensanctions.org)
The OpenSanctions platform, including its advanced search, API, bulk data access, and documentation, is a critical component of our strategy, repurposed from a defensive compliance tool into an offensive intelligence weapon. Our strategic objective is to conduct deep due diligence on every individual and entity connected to the Air Europa bailout to uncover any undisclosed risks, conflicts, or illicit connections that would provide us with overwhelming leverage. The protocol is to systematically vet all key persons of interest against global sanctions lists, lists of Politically Exposed Persons (PEPs), and their known associates.
Our researchers will execute precise searches using the advanced search interface. For each target, such as Víctor de Aldama, José Luis Ábalos, Koldo García Izaguirre, Javier Hidalgo, and even Begoña Gómez Fernández, we will search their full legal names and any known aliases. The search will be filtered by “Schema” to specifically query the “Person” and “Company” datasets. We will also filter by “Country” to focus on Spain, but will conduct follow-up global searches to trace any international links. For corporate entities like Globalia Corporación Empresarial SA and Air Europa Holding SLU, we will search for the entities themselves and then pivot to search for their identified directors and ultimate beneficial owners.
The expected evidentiary outcome is to determine if any of these individuals qualify as a PEP, which would heighten the scrutiny on the conflict of interest and potential for corruption. More critically, a finding that any involved party is listed on a sanctions list or has direct connections to sanctioned entities would fundamentally change the nature of the case, introducing national security and anti-money laundering dimensions that would make the government’s position untenable and settlement an urgent necessity. The API and bulk data documentation will be used to explore possibilities for integrating this screening process into our own systems for continuous monitoring of all parties involved.
Platform: Global Trade Alert Data Center (globaltradealert.org/data-center)
As outlined in our CaseLink Doctrine, the Global Trade Alert platform is our primary tool for executing the “USP-to-WTO” playbook. While tangential to the core Air Europa bailout infringements, it allows us to build a wider portfolio of public interest cases. The granular search strategy requires our researchers to use the Data Center to identify protectionist and harmful trade interventions. We will filter by “Implementing Jurisdiction,” selecting Spain and other relevant EU countries. We will further filter by “Intervention Type,” selecting “harmful,” and by “Affected Sectors,” focusing on codes related to air transport, tourism, and logistics. For each harmful measure identified, we will determine the specific WTO articles being violated, with a focus on GATT Article III.4 (National Treatment) as per our doctrine. The goal is to identify instances where the distorted market created by the Air Europa bailout and similar state aid packages may have contributed to or been protected by these harmful trade measures. The ultimate objective is to package these findings into an Unsolicited Proposal for a harmed nation’s government, offering COCOO’s services to manage a WTO dispute, thereby creating a new revenue stream from a public contract.
Platform: Mayer Brown Industries Page (mayerbrown.com/en/industries)
This URL leads to the website of a major international law firm. This platform is not a database for evidence gathering but a source of competitive and strategic intelligence. The granular strategy here is not one of keyword searching, but of analytical review. Our researchers will analyze the firm’s detailed descriptions of its Aviation, Antitrust & Competition, and Public Policy practice groups. We will identify their key lawyers in these fields, particularly in their Brussels and London offices, and review their publications, articles, and client alerts. The objective is to understand their public positions on EU state aid, airline competition, and government regulation. This intelligence serves two purposes. First, it helps us anticipate the legal arguments that sophisticated counterparties, like the Spanish government or IAG, might deploy, allowing us to preemptively strengthen our own claims. Second, it allows us to assess whether Mayer Brown or its lawyers are currently representing any of the parties involved in our case or their major competitors, which is vital for mapping the landscape of legal representation.
Platform: UK Companies House (find-and-update.company-information.service.gov.uk)
This is the definitive public register for UK companies and a foundational tool in our intelligence arsenal. The granular search strategy will be multi-layered. First, we will conduct a precise entity search for International Airlines Group PLC using its company registration number to access its complete filing history. We will download and analyze its annual reports and confirmation statements to identify all directors and persons with significant control. Second, we will execute our network mapping protocol: the name of each IAG director will be searched again in Companies House to map their other UK directorships, revealing potential conflicts or connections. Third, we will use the advanced search function to search by SIC code for the “Scheduled passenger air transport” sector. The goal of this is to compile a comprehensive list of IAG’s UK-based competitors to identify additional potential claimants for our collective action. The expected evidentiary outcome is a complete and documented history of IAG’s corporate governance and structure, and a validated list of UK airline competitors who were harmed by the market distortion caused by the Air Europa bailout.
Platform: Spanish Commercial Registry (sede.registradores.org)
This is the official source for Spanish company data and is of paramount importance to our case. Our granular strategy here mirrors the Companies House protocol but is focused on the Spanish entities. We will execute searches for the legal entities Globalia Corporación Empresarial SA, Air Europa Holding SLU, and Wakalua. The primary objective is to obtain official, certified copies (notas simples informativas or full certifications) of their corporate records. These documents will provide legally admissible evidence of their dates of incorporation, registered addresses, corporate objects, and, most importantly, a complete and historical list of their registered directors (administradores). This official data is non-negotiable proof of who was in control of these companies and when. We will cross-reference these findings with data from OpenCorporates to ensure completeness. The evidentiary goal is to establish a definitive, unchallengeable timeline of corporate control, which is essential for proving the sequence of events, particularly the timing of meetings between company directors and politically exposed persons.
Platform: US SEC EDGAR Database (sec.gov/edgar/searchedgar/legacy/companysearch.html)
The EDGAR database is the repository for filings of US-listed companies. The granular search strategy will focus on any entities involved in the case that have a US listing or have issued securities in the US market. While IAG is primarily UK/Spanish, we will conduct a search to confirm its filing status. More importantly, we will search for major competitor airlines that are US-listed, such as Delta Air Lines, United Airlines, and American Airlines, as well as major logistics companies like FedEx and UPS. The search will cover the period from 2019 to the present, and we will analyze their annual reports (Form 10-K) and quarterly reports (Form 10-Q). We will use keywords like “Spain,” “Air Europa,” “IAG,” “competition,” and “state aid.” The goal is to find any disclosures where these US competitors discuss the impact of European state aid on their transatlantic routes and competitive position. Finding such a disclosure would provide powerful, independent evidence from a highly credible source about the market-distorting harm caused by the bailout, significantly strengthening our case for damages.
Platform: GlobalSpec (globalspec.com/search/products?categoryIds=5346)
This platform appears to be a search engine for engineering and industrial products and services, which is outside our typical intelligence toolkit. However, a granular and creative strategy can still be applied. The objective here is exploratory, aimed at identifying potential corporate victims in niche industrial sectors that rely heavily on air freight. The MA DISCLOSURES.pdf paper noted that many undisclosed mergers occur in industrial and manufacturing sectors. We will use this platform to identify leading Spanish and UK companies within specific industrial categories that manufacture high-value or time-sensitive goods, for whom competitive air cargo pricing is a critical business input. For example, we can search for manufacturers of medical devices or aerospace components. The goal is to identify a new class of potential claimants who may have suffered indirect financial harm from reduced competition and potentially higher prices in the air cargo market resulting from the bailout and proposed IAG merger. This demonstrates a deep and thorough approach to identifying all possible avenues for our FOC DAM strategy.
Platform: Public Sector (publicsector.co.uk)
This platform, identified in our CaseLink Doctrine as OSCAR, serves as a broad database of UK public sector information. Our objective here is twofold: to identify potential UK public contracts that COCOO could pursue by leveraging our expertise from this case, and to find any UK-based entities or public bodies that may have been affected by or have commented on the Air Europa bailout or the subsequent competition distortions. The search strategy will involve using keywords from our findings, such as “airline competition,” “illegal state aid,” “Competition and Markets Authority,” and “aviation market distortion.” We will also search for any reports or publications by UK public bodies that reference the FASEE fund or the EU’s state aid decisions during the pandemic. The goal is to uncover any UK-centric angle or overlooked victim class that could strengthen a UK-based claim or provide further evidence of the bailout’s anti-competitive effects on the wider European market.
Platform: GOV.UK Advanced Search (gov.uk/search/advanced)
This is the central portal for all UK government departments and is a cornerstone of our “Enforcement Gap” strategy. Our search strategy here is to meticulously cross-reference regulatory action with stated policy. We will execute advanced searches using exact phrases like “Competition and Markets Authority,” “Air Europa,” and “IAG Iberia merger.” We will filter results by department, focusing on the Department for Business and Trade and the CMA. The primary goal is to locate policy documents, market studies, and official responses to consultations regarding the airline industry’s competitiveness between 2020 and 2024. Specifically, we are looking for any official UK government analysis of the IAG-Air Europa merger’s potential impact on UK routes, or any reports on the effects of EU state aid in the aviation sector on UK carriers. Finding a discrepancy between a stated policy of promoting competition and a failure to act or comment on this significant market distortion provides powerful evidence for a claim against the regulator itself for failure in its statutory duty.
Platform: European e-Justice Portal – Advanced Search (e-justice.europa.eu/advancedSearchManagement)
The e-Justice portal provides access to legal information across the EU. The strategy here is to search for interconnected legal proceedings and business data. We will use the advanced search functions to query for cases involving “Air Europa,” “Globalia,” “SEPI,” and “FASEE” across all member state justice systems. We are specifically looking for any litigation, insolvency proceedings, or commercial disputes that may have been initiated in other EU jurisdictions by competitors, suppliers, or other creditors. Uncovering such proceedings would provide invaluable evidence of the harm caused by the bailout and could identify other claimants for our FOC DAM strategy. The search will also target any public notices or judicial decisions that reference the financial state of Air Europa or its subsidiaries prior to 2020, which could serve as direct evidence for our central claim that the company was already a “company in crisis”.
Platform: European e-Justice Portal – Business Registers (e-justice.europa.eu/topics/registers-business-insolvency-land/business-registers-search-company-eu_en)
This search functionality is our gateway to official company information across the EU, supplementing our use of OpenCorporates. The primary strategy is verification and network mapping. We will execute searches for “Air Europa Holding SLU” and “Globalia Corporación Empresarial SA” to retrieve their official registration details in Spain and link to any other EU jurisdictions where they have registered branches or subsidiaries. We will pay close attention to the list of registered directors and any filed financial accounts. The goal is to cross-verify the corporate structure we have mapped and to obtain official, state-sanctioned documents that confirm directorships and legal status. This is particularly important for obtaining evidence on the timeline of the creation of Air Europa Holding S.L.U. and its initial directorship, which is relevant to understanding the structure of the bailout transaction.
Platform: EC Competition Case Search (competition-cases.ec.europa.eu/searchCaseInstruments)
This portal is a primary source for our legal analysis of EU competition law. Our search strategy is to conduct a deep-dive analysis of all case documents related to EU state aid in the airline sector during the pandemic. We will search using case numbers for the Air Europa state aid approval (SA.59125) and the related IAG/Air Europa merger cases (M.9637 and M.11046). Beyond this, we will search for cases involving competitors like Lufthansa, Air France-KLM, and TAP Air Portugal to identify the Commission’s reasoning and potential inconsistencies in its application of the “company in crisis” criteria. The goal is to find procedural errors or patterns of weak analysis by the Commission that could be used to challenge the legality of the Air Europa decision itself, in line with our “JR. CAT, ECJ” strategy. We will scrutinise the “public consultations” page to see if COCOO or other parties can still “Have your say” on related matters, potentially opening another avenue for intervention.
Platform: db-comp.eu
This is an independent database of EU competition law decisions. Our strategy here is one of cross-validation and deeper analysis. We will use this platform to search for the same cases identified for the official EC portal. The goal is to see if this independent database offers different document versions, more accessible formatting, or expert commentary and analysis that is not available on the official CURIA or EC sites. We will search for keywords from our findings, such as “distressed undertaking,” “conflict of interest,” “one time last time principle,” and “proportionality of aid,” within the text of Commission and Court decisions related to airline bailouts. This provides a secondary source to ensure our analysis of the legal precedent is comprehensive and to potentially find academic or professional commentary that supports our legal arguments.
Platform: EU Trade Policy Hub (policy.trade.ec.europa.eu)
This platform is central to our “USP-to-WTO” playbook, allowing us to identify illegal trade barriers. While not directly related to the core infringement of the Air Europa bailout, the strategy here is to identify parallel opportunities for COCOO. We will use the portal’s database of reported trade barriers to search for any measures affecting the aviation or tourism sectors. We will filter by “Harmful” intervention types and look for any EU-level policies or disputes that may have been influenced by the distorted market resulting from state aid like the Air Europa rescue. The goal is to explore whether the bailout had secondary effects that could be framed as a trade barrier, or to simply use this tool as described in our CaseLink Doctrine to originate new, unrelated cases that can be funded by public contracts, thereby supporting COCOO’s overall operational capacity.
Platform: EU ITAS (eu.itas.by.nation)
The search link appears to be for a database related to international trade agreements or statistics. Our strategy here will be to use this tool to quantify the economic impact of the market distortion. We will search for trade flow data and statistics related to passenger and cargo air transport for Spain and the UK, focusing on the period from 2019 to 2024. The goal is to identify statistical anomalies in market share, capacity, or pricing on routes where competitor airlines were harmed by Air Europa’s state-supported continuation. This data is essential for the “Evaluation of the Daño” (damage assessment) phase of our case, providing the quantitative evidence needed to substantiate our claims for financial compensation in any future litigation or mediation. It helps us move from alleging harm to proving it with hard numbers.
Platform: Investegate Advanced Search (investegate.co.uk/advanced-search)
This platform is a key tool in our “RNS OC OS” strategy for monitoring UK-listed companies. The primary target here is International Airlines Group (IAG), which is listed on the London Stock Exchange. Our search strategy is to use the advanced search to filter for all announcements by IAG (EPIC code: IAG) from November 2019 to the present. We will use specific keywords from our findings, including “Air Europa,” “Globalia,” “SEPI,” “indemnización,” “break fee,” and “renegotiation.” We will pay close attention to announcement categories like “Mergers, Acquisitions and Disposals” and “Holding(s) in Company”. The goal is to build a precise, documented timeline of IAG’s actions and public statements regarding the acquisition. This will provide direct evidence of how the deal’s terms, valuation, and payment schedule evolved in direct relation to the granting of the state aid, which is fundamental to our cause of action for misuse of public funds.
Platform: OpenCorporates Companies (opencorporates.com/companies)
This is our primary tool for global corporate network mapping, as detailed in our CaseLink Doctrine. The search strategy is to execute the full protocol outlined in the Doctrine. We will perform searches for the corporate entities “Air Europa Holding SLU,” “Globalia Corporación Empresarial SA,” and “Wakalua.” We will then conduct separate officer searches for the individuals “Javier Hidalgo,” “José Luis Ábalos,” “Koldo García Izaguirre,” “Víctor de Aldama,” and “Begoña Gómez Fernández”. For each officer, we will meticulously trace all other current and former directorships globally to identify hidden connections or shared corporate vehicles. The goal is to uncover the complete, multi-jurisdictional network of influence and to provide evidence of potential conflicts of interest or coordinated action that would not be apparent from examining a single company in isolation. This directly supports our allegations of influence peddling and conflict of interest.
Platform: OpenCorporates Registers (opencorporates.com/registers)
This part of the platform provides information on the various corporate registries from which OpenCorporates sources its data. Our strategy here is not one of searching for companies, but of assessing the quality and accessibility of the source data. We will review the details for the Spanish commercial registry (Registro Mercantil) and registries in any other jurisdictions that our primary searches reveal to be relevant (e.g., offshore jurisdictions). The goal is to understand the limitations of the available data. For example, does a particular registry provide director birth dates for unique identification? Is the data updated frequently? This information is crucial for assessing the strength of our evidence and identifying where we may need to file direct requests with the national registries themselves to obtain certified documentation to support our claims in a formal legal setting.