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The RADON CASE: A Collective Action Against State Negligence


SEARCHLINKS



1. Searchlink: https://cocoo.uk/2025/06/19/www-opencorporates-com/

  • The Standard Model: The doctrine for OpenCorporates is to use its global open database to conduct in-depth investigations of corporate structures. The model involves searching for a target company, then systematically mapping out its entire corporate tree, including parent companies, subsidiaries, branch offices, and registered agents, using the interconnected data to trace networks of ownership and control across multiple jurisdictions.
  • Customisation for the RADON CASE: This model is applied directly to the Spanish construction and real estate sectors. The strategy is to conduct a full corporate mapping of the largest players (e.g., ACS, Acciona, Ferrovial, Sacyr, Metrovacesa, Neinor Homes). The objective is to identify all their domestic and international subsidiaries. This comprehensive map will be used to ensure legal notices for the collective action are served to every relevant corporate entity, to identify potential conflicts of interest, and to understand the full scale of the corporate actors who have benefited from the lack of radon regulation.

2. Searchlink: https://cocoo.uk/2025/06/19/os/ (linking to OpenSanctions)

  • The Standard Model: The standard procedure for OpenSanctions is to use its global database of sanctions lists, politically exposed persons (PEPs), and other persons of interest as a critical due diligence tool.1 The model involves searching for both individuals and corporate entities to check for any red flags that might indicate connections to illicit activities, corruption, or sanctions violations.2
  • Customisation for the RADON CASE: The model is customized for due diligence on the key actors in Spain. The search will target the board members and executive leadership of the major Spanish construction firms identified via OpenCorporates. Additionally, we will search for the names of high-ranking officials in the Spanish ministries responsible for housing, health, and industry. The objective is to produce a due diligence report that confirms whether any key players are on sanctions lists or are listed as PEPs, which is essential for understanding political connections and mitigating future risks to the case.

3. Searchlink: https://cocoo.uk/2025/06/19/www-stealthconsolidation/

  • The Standard Model: The standard model for this resource is to apply its conceptual framework of “stealth consolidation” to a target market. This involves looking beyond major, publicly-announced mergers to identify a pattern of smaller, under-the-radar acquisitions and company failures that lead to a gradual increase in market concentration and a decrease in competition over time.
  • Customisation for the RADON CASE: The framework is applied to the Spanish construction and environmental remediation/testing sectors. The strategy is to use data gathered from business registries and news archives to analyze the rate of company formation, acquisition, and failure in these sectors over the last decade. The objective is to build a narrative, supported by data, that the state’s failure to regulate radon has created a market where only large, entrenched players can survive, thereby stifling the growth of a competitive market for specialized safety and remediation services.

4. Searchlink: https://cocoo.uk/2025/06/19/nac-sic-gpt/

  • The Standard Model: The doctrine for a NACE/SIC code classification tool is to use it as a foundational step in any sectoral investigation. The model involves inputting a company’s name or business description to receive its precise Standard Industrial Classification code, ensuring that all subsequent searches on official statistical or business databases are accurate and comprehensive.
  • Customisation for the RADON CASE: This model is applied to ensure analytical precision. The strategy is to use the tool to get the definitive Spanish/EU economic activity codes (CNAE) for every company of interest. We will specifically identify the codes for “Construction of residential buildings” (CNAE 41.21), “Real estate development” (CNAE 41.10), “Real estate agencies” (CNAE 68.31), and “Technical testing and analysis” (CNAE 71.20). This definitive list of codes is mandatory for conducting accurate, filtered searches on platforms like Eurostat and the Spanish business registries.

5. Searchlink: https://cocoo.uk/2025/06/19/www-globaltradealert-org/

  • The Standard Model: The standard procedure for Global Trade Alert is to use its database to monitor state interventions that affect trade. The model involves searching for a specific country and sector to identify protectionist measures, subsidies, or other government policies that could create an unfair advantage for domestic industries.
  • Customisation for the RADON CASE: This model is customized to search for state interventions that exacerbate the radon problem. We will search the database for any Spanish government subsidies, grants, or tax breaks provided to the housing and construction sectors. The objective is to identify instances where the state has actively provided financial incentives for the construction of new housing without any corresponding requirement for radon safety checks. This evidence would counter any defense of passive ignorance and instead build a case of active, financially-supported negligence.

6. Searchlink: https://cocoo.uk/?direct_file=... (specific internal files)

  • The Standard Model: The doctrine for an internal file link is that it represents a piece of proprietary, pre-compiled evidence or analysis that is core to the case. The model requires that this internal asset be located and its contents fully integrated into the broader investigation strategy.
  • Customisation for the RADON CASE: For the Radon Case, these internal files (e.g., NIPO_20__Methodology.pdf) represent foundational pillars of the project. The strategy is to treat them as the source of our primary claims. For example, the methodology PDF would be the basis for our scientific and economic damage calculations, while an internal spreadsheet would contain the detailed workings of the €23.97 billion damage estimate. They are not platforms for searching, but source documents to be defended and evidenced by the external search results.

7. Searchlink: https://cocoo.uk/2025/06/19/www-mayerbrown/

  • The Standard Model: The COCOO-Mayer Brown Doctrine is a strategic model for competitor and adversary intelligence. The model involves treating the public-facing thought leadership (articles, client alerts) of a major law firm not as a database, but as a source of strategic intelligence to understand how sophisticated legal opponents frame arguments and view legal risks in a particular sector.
  • Customisation for the RADON CASE: For this case, the adversary is the Spanish state. The model is therefore customized to anticipate the state’s legal defense. The strategy is to search Mayer Brown’s publications for keywords like "sovereign liability", "state responsibility", "EU law infringement", and "mass tort defense". The objective is to build a “red team” report that outlines the most likely legal arguments the Spanish government’s lawyers will use, allowing COCOO to prepare counter-arguments and strengthen its case preemptively.

8. Searchlink: https://cocoo.uk/2025/06/19/www-companieshouse/

  • The Standard Model: The COCOO-Companies House Doctrine is a model for using the UK’s official company register for strategic sectoral analysis. It emphasizes using the Advanced Search function, particularly filtering by SIC code, to dissect an entire industry, identify all players, and detect market trends like consolidation.
  • Customisation for the RADON CASE: The model is customized for benchmarking and identifying cross-border actors. The strategy has two prongs. First, we will use the advanced search to identify all UK companies with the SIC code for “environmental consulting” or “remediation services” to create a directory of potential expert witnesses. Second, we will search for any major Spanish construction firms that have a registered UK entity. We will then compare the list of company directors in the UK with the Spanish parent company to identify key individuals with cross-jurisdictional responsibilities.

9. Searchlink: https://cocoo.uk/2025/06/19/rns-oc-os/

  • The Standard Model: The COCOO-LSE Doctrine outlined here is a model for using the London Stock Exchange’s data for real-time market intelligence. The core is to monitor the Regulatory News Service (RNS) for early signals of corporate action. The OC-OS part of the doctrine signifies that any significant RNS finding immediately triggers a follow-up investigation using OpenCorporates (OC) and OpenSanctions (OS).
  • Customisation for the RADON CASE: The model is customized to focus on UK-listed firms with Spanish exposure. We will set up alerts on the RNS for any company identified in our previous searches as having significant Spanish real estate or construction interests. Any announcement mentioning their Spanish operations (e.g., asset write-downs, new investments, comments on market conditions) will immediately trigger the OC-OS pipeline to check for corresponding changes in their corporate structure or for any new sanctions-related intelligence on their directors.

10. Searchlink: https://cocoo.uk/2025/06/19/www-sede-registradores-org/

  • The Standard Model: The doctrine for the Spanish Registradores ecosystem is to use its three main components in conjunction. First, the core registry (sede.registradores.org) is used to pull basic details and official filings on a specific company. Second, the Estadísticas Mercantiles portal is used to analyze aggregated financial data for an entire sector (filtered by CNAE code). Third, the Ratios Sectoriales portal from the Banco de España is used to get detailed financial health ratios for that sector.
  • Customisation for the RADON CASE: This model is applied directly and is fundamental to the case. We will first use the core registry to pull the full company profiles (Nota Simple) for our target list of Spanish construction firms. We will then use the statistics portal, filtered by the relevant CNAE codes (e.g., 41.21, 41.10), to get an official, aggregated view of the financial scale of the entire sector. Finally, we will use the financial ratios portal to analyze the overall economic health and vulnerability of the sector, which supports our damage calculations.

11. Searchlink: https://cocoo.uk/2025/06/19/www-sec-edgar/

  • The Standard Model: The standard model for the SEC EDGAR database is to search the filings of US-publicly traded companies to gather financial data, identify corporate strategies, and find disclosures of material risks. Key documents are the 10-K (annual report), 10-Q (quarterly report), and 8-K (material events).
  • Customisation for the RADON CASE: The model is customized to find evidence from non-US companies that have a US listing. The strategy is to identify any major Spanish construction, banking, or insurance firms (e.g., Banco Santander, Ferrovial) that are traded on a US exchange. We will then conduct a full-text search of their SEC filings (10-K, 20-F for foreign issuers) for keywords "Spain", "radon", "environmental liability", "real estate risk", and "regulatory compliance". The objective is to find any risk disclosures made to US investors that are not as prominent in their Spanish-language reporting.

12. Searchlink: https://cocoo.uk/2025/06/19/www-globalspec-com/

  • The Standard Model: The standard model for GlobalSpec, an engineering and industrial products search engine, is to identify the technical specifications, manufacturers, and “state of the art” for specific industrial products and components.
  • Customisation for the RADON CASE: The model is applied to prove the feasibility of the proposed solution. We will use the platform to search for all commercially available technologies for “radon detection,” “radon measurement,” “air quality testing,” and “sub-slab depressurization systems.” The objective is to compile a technical dossier of existing, off-the-shelf solutions. This dossier will be used as evidence to counter any potential argument from the Spanish state that implementing a nationwide remediation program is technically unfeasible or requires technology that is not readily available.

13. Searchlink: https://cocoo.uk/2025/06/19/www-trade-ec-europa-eu/

  • The Standard Model: The doctrine for the EU’s Access to Markets portal is to provide businesses with information on trade conditions. The model involves searching for a specific country and product/service to find information on tariffs, customs procedures, and, crucially, non-tariff barriers to trade.
  • Customisation for the RADON CASE: This model is customized to identify Spain’s regulatory failure as a non-tariff barrier. The strategy is to search for rules and regulations for “construction services” and “environmental testing services” in Spain. We will then argue that the absence of a mandatory radon regulation framework constitutes a barrier, as it creates market uncertainty and disadvantages companies from other EU countries where such standards are the norm. This intelligence supports the parallel legal strategy of lodging a formal complaint with the Commission.

14. Searchlink: https://cocoo.uk/2025/06/20/www-showvoc-op-europa-eu/

  • The Standard Model: The standard model for this EU vocabularies platform is to use it as a reference tool to ensure the use of correct, official EU terminology in legal and technical documents. It allows searching for official definitions and translations of concepts across all EU languages.
  • Customisation for the RADON CASE: This model is applied as a foundational step for ensuring legal precision. The strategy is to search for and verify the official definitions and taxonomies for terms like "ionising radiation", "reference level", "remediation", "public health", and "environmental harm" as defined within the Eurovoc thesaurus. This ensures that all legal submissions and expert reports produced for the Radon Case use the precise, official terminology of the EU institutions, preventing any ambiguity or definitional challenges.

15. Searchlink: https://cocoo.uk/2025/06/19/www-eurostat/

  • The Standard Model: The standard procedure for using Eurostat, the EU’s statistical office, is to extract large-scale, credible datasets to provide a quantitative, macroeconomic context for a specific issue. The model involves searching its databases by theme, country, and time period to build statistical evidence.
  • Customisation for the RADON CASE: The model is applied to provide the quantitative backbone for the entire claim. We will query the Eurostat databases for Spanish-specific data on several key indicators: new residential construction rates, public health statistics (specifically lung cancer incidence and mortality rates), housing stock details (age, type), and economic indicators for the construction sector. This official data will be used to build models that directly support the €23.97 billion damage calculation and to demonstrate the immense scale of the public health and economic problem.

16. Searchlink: https://cocoo.uk/2025/06/19/www-usp-wpi/

  • The Standard Model: The doctrine for using a major patent database like the Derwent World Patents Index (WPI) is to investigate the global innovation landscape for a specific technology. The model involves using keyword and classification code searches to identify all relevant patents, the companies that own them, and the jurisdictions where they are protected.
  • Customisation for the RADON CASE: The model is applied to demonstrate the maturity of remediation technology. The strategy is to conduct a global patent search for all technologies related to “radon mitigation,” “radon testing,” and “soil gas depressurization.” The objective is twofold: first, to create a report showing the vast number and age of existing technological solutions, proving their maturity and availability. Second, to specifically check if Spanish companies have filed such patents, with a lack of filings indicating that the regulatory failure has suppressed domestic innovation.

17. Searchlink: https://cocoo.uk/2025/06/19/www-violationtrackeruk/

  • The Standard Model: The standard procedure for Violation Tracker UK is to use its database of corporate misconduct to build a “rap sheet” on a target company. The model involves searching for a company name to find its history of regulatory breaches in the UK, including employment tribunals, health and safety convictions, and environmental notices.
  • Customisation for the RADON CASE: The model is customized for comparative corporate analysis. The strategy is to search the database for any of the major Spanish construction firms that have a significant operational presence in the UK (e.g., Ferrovial). The objective is to find their UK compliance history. A report showing that a company adheres to high health and safety standards in the regulated UK market provides a powerful contrast to their practices in the unregulated Spanish market, supporting the argument that corporate behavior is a function of state enforcement.

18. Searchlink: https://cocoo.uk/2025/06/19/www-cat/

  • The Standard Model: The standard model for using the UK’s Competition Appeal Tribunal (CAT) archives is to find direct legal precedents for competition law cases, focusing on how the Tribunal has interpreted specific sections of competition legislation.
  • Customisation for the RADON CASE: The model is adapted to search for precedents on legal principle rather than on fact. The strategy is to search the CAT’s case archive not for radon cases, but for judicial reviews of regulator decisions or cases that hinged on the interpretation of an EU directive. The objective is to find judgments that discuss the duties of a public body under EU-derived law and the standard of review for regulatory inaction. This provides jurisprudential arguments that can be cited persuasively in the Spanish legal proceedings.

19. Searchlink: https://cocoo.uk/2025/06/19/www-cma-gov-uk/

  • The Standard Model: The doctrine for using the UK’s Competition and Markets Authority (CMA) website is to find information on ongoing market investigations, merger decisions, and, crucially, the CMA’s official guidance on how it interprets its legal duties.
  • Customisation for the RADON CASE: The model is customized for benchmarking best practices. The strategy is to search the CMA’s website for any and all guidance documents it has published regarding consumer protection, public health considerations in markets, and its duties to enforce safety-related regulations. The objective is to compile a report detailing how a best-in-class, independent regulator defines its responsibilities. This report will be used as a “gold standard” benchmark to highlight the profound failures of the corresponding Spanish state bodies.

20. Searchlink: https://cocoo.uk/2025/06/19/www-dgcomp/

  • The Standard Model: The standard model for the European Commission’s DG COMP website is to search its case archives for precedents in EU competition law, particularly merger control and state aid decisions.
  • Customisation for the RADON CASE: The model is adapted to focus on a different area of DG COMP’s parent body’s responsibility: infringement proceedings. The strategy is to search the Commission’s wider databases (linked from DG COMP’s site) for all historical infringement proceedings launched against Spain, or any other member state, for failure to correctly implement environmental or public health directives. The objective is to find legal documents and press releases that show how the Commission legally constructs such cases, providing a template for COCOO’s own arguments.

21. Searchlink: https://cocoo.uk/2025/06/19/www-bailii/

  • The Standard Model: The standard model for using the British and Irish Legal Information Institute (BAILII) is to conduct free, broad searches for UK and Irish case law to find legal precedents.
  • Customisation for the RADON CASE: The model is applied to find persuasive, common-law authority on the core legal principles of the case. The strategy is to conduct a detailed search for UK case law on the “tort of negligence by a public body” and “breach of statutory duty,” specifically in cases involving a public health risk. The objective is to create a legal brief of supporting precedents that, while not binding in Spain, can be presented to the Spanish court to demonstrate how a similar legal system has dealt with the question of state liability.

22. Searchlink: https://cocoo.uk/2025/06/19/www-eur-lex/

  • The Standard Model: The standard procedure for EUR-Lex is to use it as the definitive source for all official EU legal documents, including treaties, directives, regulations, and court judgments.3
  • Customisation for the RADON CASE: This model is applied directly and is non-negotiable for establishing the primary evidence. The strategy is twofold. First, to download the full, consolidated text of Council Directive 2013/59/Euratom in all relevant languages. Second, and most critically, to download the complete, official judgment from the Court of Justice of the European Union in case C-384/22. These two documents form the immutable legal foundation upon which the entire Radon Case is built.

23. Searchlink: https://cocoo.uk/2025/06/19/www-uks-business-and-property-courts/

  • The Standard Model: The model for using the archives of the UK’s specialist Business and Property Courts is to search for judgments in high-value, complex commercial disputes that may provide precedents.
  • Customisation for the RADON CASE: The model is adapted to find cases based on legal principle. The strategy is to search the court’s case archives for any disputes that touch upon damages arising from non-compliance with statutory duties or regulatory failure in a commercial context (e.g., environmental contamination cases). The objective is to find judicial reasoning on how damages are calculated in complex cases of negligence, which can inform the financial models for our own claim.

24. Searchlink: https://cocoo.uk/2025/06/20/www-companieshouse-find-company-info/ (Advanced Search)

  • The Standard Model: The model for the Companies House advanced search is to combine multiple filters (e.g., location, incorporation date, company status, SIC code) to isolate very specific cohorts of companies for analysis.
  • Customisation for the RADON CASE: The model is customized to find highly specific UK companies for benchmarking and expertise. The strategy is to use the advanced search to filter for all active UK companies with an SIC code for “Testing and measurement” or “Environmental consulting services” that were incorporated more than 10 years ago. This will create a vetted list of experienced, credible firms that could be approached to act as expert witnesses on the technical and commercial feasibility of a nationwide radon testing program.

25. Searchlink: https://cocoo.uk/2025/06/20/www-ukparl-interest-disclosures/

  • The Standard Model: The standard model for the UK Parliament’s Register of Members’ Financial Interests is to search for the disclosures of specific politicians or to search across the register for mentions of specific companies to identify potential conflicts of interest or channels of corporate influence.
  • Customisation for the RADON CASE: This model is applied for contextual political intelligence. The strategy is to search the register for any declared interests (shareholdings, directorships) held by UK MPs in the major construction or real estate firms with operations in Spain. The objective is not to find a direct link to radon, but to map the political affiliations and networks of the key corporate players, which provides valuable context for the overall case.

26. Searchlink: https://cocoo.uk/2025/06/19/www-ec-europa-eu-haveyoursay/

  • The Standard Model: The standard procedure for the EU’s “Have Your Say” portal is to search its archives for past public consultations and citizen feedback initiatives related to a specific piece of legislation or policy area.
  • Customisation for the RADON CASE: This model is applied to find prior warnings and build a history of the issue. The strategy is to search the portal meticulously for any past consultations, feedback, or petitions related to Directive 2013/59/Euratom, radiation safety, or environmental health in Spain. The objective is to find and document any evidence submitted by other NGOs, professional bodies, or citizen groups that raised concerns about Spain’s implementation of the radon directive. This would prove that the state was put on notice of the problem long before our legal action.

27. Searchlink: https://cocoo.uk/2025/06/19/www-caselaw-nationalarchives-gov-uk/

  • The Standard Model: The model for the UK’s National Archives case law service is to use it as a primary source for finding significant historical judgments and legal records, particularly those that have set major precedents.
  • Customisation for the RADON CASE: The model is applied to find foundational UK legal precedents on state liability. The strategy will be to search for seminal cases concerning the tort of negligence by a public authority, particularly landmark House of Lords or Supreme Court rulings that defined the scope of a government’s “duty of care” to its citizens in matters of public safety. The objective is to build a brief of the most powerful supporting case law from a leading common law jurisdiction.

28. Searchlink: https://cocoo.uk/2025/06/20/www-consult-lobbyist-reg-uk/ and www-scot-lobby-reg

  • The Standard Model: The standard model for the UK and Scottish lobbying registers is to search for lobbying activities undertaken by specific companies or targeting specific government departments to map patterns of corporate influence.
  • Customisation for the RADON CASE: The model is applied for comparative corporate profiling. The strategy is to search these registers for any lobbying activities conducted by the major Spanish construction firms with UK operations. We will look for their engagement on topics like environmental regulations or building standards. A report showing that these firms actively lobby on safety standards in the UK provides a stark contrast to the situation in Spain and helps build a narrative about their corporate priorities.

29. Searchlink: https://cocoo.uk/2025/06/19/www-casetracker-gov-uk/

  • The Standard Model: The standard model for a government case tracker is to monitor the progress of specific ongoing government projects, investigations, or legal cases.
  • Customisation for the RADON CASE: This model is applied for benchmarking project management and transparency. We will search the UK’s Casetracker system for examples of large-scale public health or environmental remediation projects. The objective is to analyze and report on the typical timelines, budgets, stakeholder engagement processes, and public reporting standards for such a project in the UK. This provides a clear, practical model of responsible governance that can be contrasted with the administrative vacuum in Spain.

30. Searchlink: https://www.hl.co.uk/funds and https://www.ajbell.co.uk/markets

  • The Standard Model: The standard model for using investment platforms like Hargreaves Lansdown and AJ Bell is to utilize their fund and share screening tools to identify which institutional investors and asset managers have significant holdings in specific companies or sectors.
  • Customisation for the RADON CASE: The model is applied to map the key financial stakeholders. The strategy is to use the screeners to identify all UK and European investment funds with a stated focus on Iberian real estate or with significant holdings in the major Spanish construction firms. The objective is to create a list of the key asset managers who have a fiduciary duty to manage risk. This intelligence can be used to open a dialogue with these powerful investors, making them aware of the systemic radon liability they may be exposed to.

31. Searchlink: https://cocoo.uk/2025/06/19/www-causelist-gov-uk/

  • The Standard Model: The standard model for a court’s Cause List is to perform daily checks to monitor the scheduling of upcoming hearings, judicial assignments, and the progress of active litigation.
  • Customisation for the RADON CASE: This model is applied for case management and monitoring, not primary research. The strategy is to have this platform on a watch list. Should any part of the Radon Case (e.g., an enforcement action) reach the UK courts, or if related cases appear, this platform would be checked daily to track all procedural developments.

32. Searchlink: https://cocoo.uk/2025/06/19/www-find-tender-service-gov-uk/ and www-contractsfinder-gov-uk

  • The Standard Model: The standard procedure for UK public procurement portals is to search for past and present tender opportunities to understand government purchasing patterns, identify competitors, and find contract award notices which contain details on value and scope.
  • Customisation for the RADON CASE: The model is applied for crucial financial benchmarking. The strategy is to conduct an exhaustive search of these portals for every public contract related to “radon testing,” “radon remediation,” and “radiological assessment.” The objective is to compile a detailed database of real-world contract values and work specifications. This data will be used to create an evidence-based, highly credible budget for the public-private partnership COCOO is proposing for Spain.

33. Searchlink: https://cocoo.uk/2025/06/19/www-lobbyfacts-eu/

  • The Standard Model: The doctrine for LobbyFacts.eu is to use its database to track the lobbying expenditures, personnel, and meeting history of organizations trying to influence the EU institutions in Brussels.4
  • Customisation for the RADON CASE: This model is applied directly to the key Spanish corporate actors. The strategy is to search for the profiles of all major Spanish construction firms (ACS, Ferrovial, etc.) and their primary trade associations (e.g., SEOPAN, CEOE). The objective is to analyze who they have been meeting with at the European Commission and what their declared lobbying interests are. Discovering lobbying activities aimed at weakening or delaying environmental or safety regulations would be a critical finding for the case.

34. Searchlink: https://cocoo.uk/2025/06/20/ec-commissioners-discl/

  • The Standard Model: The standard procedure for the European Commissioners’ disclosures is to review their public declarations of interest to check for any potential conflicts of interest.
  • Customisation for the RADON CASE: This model is applied as a standard but essential due diligence check. The strategy is to review the declarations of the Commissioners for Health (DG SANTE), Environment (DG ENV), and the Single Market (DG GROW), looking for any past or present financial ties or affiliations to the Spanish construction and real estate industries. The objective is to ensure the political integrity of the process and to identify any potential biases at the highest level of the Commission.

35. Searchlink: https://cocoo.uk/2025/06/20/www-eu-fundstenders/

  • The Standard Model: The standard model for the EU’s main Funding & Tenders Portal is to search for large-scale grant and contract opportunities funded by the EU budget.5
  • Customisation for the RADON CASE: The model is customized to investigate the past use of EU funds by Spain. The strategy is to search the portal’s archives for any major regional development, structural, or environmental funds awarded to Spanish public bodies. The objective is to see if Spain has received significant EU funding that could and should have been allocated to address a known environmental health risk like radon. Evidence that such funds were misallocated or used for projects that ignored the radon risk would dramatically strengthen the case for state negligence.

36. Searchlink: https://cocoo.uk/2025/06/20/www-wto-disp-settlement/

  • The Standard Model: The model for the WTO Dispute Settlement database is to search for historical cases to find precedents where one country’s domestic regulations (or lack thereof) were found to be an unfair barrier to international trade.
  • Customisation for the RADON CASE: The model is applied to find high-level legal precedents. The strategy is to search the dispute database for any past cases where a country’s failure to adhere to an international health or safety standard (like those from the WHO or IAEA) was successfully argued to be a barrier to trade in goods or services. The objective is to find rulings from a global body that connect regulatory negligence to economic harm, providing persuasive authority for our arguments.

37. Searchlink: https://cocoo.uk/2025/06/20/www-uk-parlm-petitions/

  • The Standard Model: The model for the UK Parliament’s petitions website is to search for past and present petitions on a specific topic to gauge the level of public concern and political engagement on that issue.
  • Customisation for the RADON CASE: The model is applied for comparative public interest analysis. The strategy is to search for any petitions related to “radon,” “household safety,” or “environmental health” in the UK. The objective is to demonstrate the level of public awareness and political discourse on these issues in a comparable country. This can be contrasted with the situation in Spain to argue that the lack of public outcry there is not due to an absence of a problem, but due to the state’s failure to properly inform its citizens of the risks.

38. Searchlink: https://cocoo.uk/2025/06/20/www-usa-oge-gov/

  • The Standard Model: The model for using the US Office of Government Ethics (OGE) website is to study its rules, advisory opinions, and enforcement actions to understand the framework for ethical conduct within the US executive branch.
  • Customisation for the RADON CASE: This model is used to establish a “gold standard” for governmental ethics. The strategy is to research the OGE’s regulations concerning conflicts of interest and public health responsibilities. The objective is to create a report on best practices in government ethics. This will be used as a benchmark to highlight the ethical dimensions of the Spanish state’s failure to act on a known, serious public health threat.

39. Searchlink: https://cocoo.uk/2025/06/20/www-usa-congress-lobby-discl/

  • The Standard Model: The model for the US Congress Lobbying Disclosure database is to search for lobbying reports filed by specific companies to see which legislation they are trying to influence and how much they are spending.
  • Customisation for the RADON CASE: The model is applied to investigate the global political activities of the key Spanish firms. The strategy is to search the database for any lobbying reports filed by the US subsidiaries of major Spanish construction and engineering firms (e.g., Ferrovial’s US operations). The objective is to build a profile of their political priorities and engagement strategies on a global scale.

40. Searchlink: https://cocoo.uk/2025/06/20/www-pacer-usa/

  • The Standard Model: The standard model for PACER (Public Access to Court Electronic Records) is to search the dockets of US federal courts to find litigation history for a specific company or individual.6
  • Customisation for the RADON CASE: The model is applied to build a comprehensive risk profile of the major Spanish corporate actors. The strategy is to search PACER for any federal litigation (e.g., contract disputes, environmental lawsuits, class actions) involving the US arms of the large Spanish construction firms. Their litigation history in the highly-regulated US market can provide valuable insights into their corporate behavior and attitude towards legal compliance.

41. Searchlink: https://cocoo.uk/2025/06/20/www-usaspending-gov/

  • The Standard Model: The standard procedure for USAspending.gov is to search its database to see if a specific company has been awarded contracts from the US federal government, detailing the agency, value, and purpose.
  • Customisation for the RADON CASE: The model is applied to map the international financial footprint of the Spanish firms. The strategy is to search for any US federal contracts awarded to companies like Ferrovial or ACS. This intelligence helps to build a picture of their global business relationships and their experience in the highly regulated US public procurement market, which can be contrasted with their operations in Spain.

42. Searchlink: https://cocoo.uk/2025/06/20/www-global-branddb-wipo-int/

  • The Standard Model: The model for the WIPO Global Brand Database is to search for all trademarks owned by specific companies or within a specific industry class to understand branding strategies and identify market players.
  • Customisation for the RADON CASE: The model is applied to map the commercial market for the solution. The strategy is to search for all registered trademarks globally that include the word “radon.” The objective is to identify the key commercial companies that provide radon testing and remediation services. This list of established players can be used to identify potential partners for the public-private partnership COCOO is proposing.

43. Searchlink: https://cocoo.uk/2025/06/20/www-register-openownership-org-search/

  • The Standard Model: The doctrine for the OpenOwnership register is to use its data to cut through complex corporate structures and identify the Ultimate Beneficial Owners (UBOs) of a company.
  • Customisation for the RADON CASE: This model is a critical and direct application. The strategy is to conduct a deep search for the major Spanish construction and real estate firms to trace their ownership chains to the actual people who own or control them. The objective is to identify these UBOs, which adds a powerful human and accountability dimension to the case. It helps to uncover hidden political connections and to identify the individuals who have ultimately profited from a system where public health was ignored.

44. SPANISH SEARCHLINKS (Final Batch)

  • The Standard Model and Customisation: This final set of domestic Spanish platforms is where the most direct evidence lies. The model for each is direct, forensic investigation.
    • Infocif: As a commercial company data provider, we will use it to pull detailed financial reports and credit assessments on our target Spanish firms, supplementing the official data from the registry.
    • Hacienda (COIS): We will investigate the tax authority’s information systems for any data related to the construction sector that could inform our economic damage models.
    • Congreso de los Diputados: The Spanish Parliament’s site will be searched for all records of debates, questions, and committee hearings mentioning “radon” or “Directiva 2013/59/Euratom” to build a timeline of political inaction.
    • CNMV: The stock market regulator’s archives will be searched for the annual reports of all listed real estate and construction firms to find risk disclosures (or a lack thereof).
    • CNMC: The competition authority’s website will be searched for any market studies into the construction sector that might highlight competitive distortions.
    • Transparencia Gencat: The Catalan transparency portal will be used as a regional case study to search for any environmental health data or radon-related information released at the autonomous community level.
    • Publicador Concursal / BOE: The official insolvency register and state bulletin will be searched for notices of failure of smaller construction firms and for any official decrees related to the directive, respectively.
    • Contratación del Estado: The public procurement portal will be exhaustively searched to find contracts that prove systemic negligence by failing to include radon safety clauses.
    • InfoSubvenciones: The national subsidy database will be searched to prove the state was actively funding projects that ignored the radon risk.


1. Searchlink: https://cocoo.uk/2025/06/20/www-db-comp-eu/

  • The Standard Model: The doctrine for db.comp.eu, an independent aggregator of EU merger cases, is to use it for rapid precedent analysis in competition law. The model involves identifying past merger decisions in a specific sector to understand the European Commission’s likely concerns, the types of remedies they will accept, and the probability of a deal being cleared, prohibited, or cleared with conditions. It is used to analyze market definitions and “public interest” arguments.

  • Customisation for the RADON CASE: For the Radon Case, which is a state negligence claim and not a merger, this model is customized for contextual economic analysis. The strategy is to search the database for any and all merger or state aid cases involving the major Spanish construction firms (e.g., ACS, Ferrovial, Sacyr) or the environmental services sector in Spain. The objective is not to find a direct precedent, but to gather intelligence on the market structure, the key corporate players as identified by the Commission, and any past state interventions. This intelligence will be used to build a profile of the economic landscape in which the state’s negligence occurred.


2. Searchlink: https://cocoo.uk/2025/06/19/www-policy-trade-ec-europa-eu/

  • The Standard Model: The standard model for the EU’s trade policy portal is to conduct forensic keyword searches within the legal texts of EU trade agreements. The model involves navigating to a specific country’s agreement, downloading the official PDF, and using the find function (Ctrl+F) to search for terms that represent legal risk and opportunity, such as "state-owned enterprise", "competition policy", "subsidy", and "dispute settlement".

  • Customisation for the RADON CASE: This model is customized to focus on the EU’s internal market principles rather than external trade agreements. We will search the portal for policy documents and legal texts related to the “level playing field” within the Single Market, specifically for the construction and services sectors. The forensic keyword search will be for terms like "environmental standard", "health and safety", "non-compliance", "infringement", and "level playing field". The goal is to find legal language that supports the argument that Spain’s failure to enforce the Euratom directive constitutes a distortion of the single market.


3. Searchlink: https://cocoo.uk/2025/06/19/www-eu-itas-by-nation/

  • The Standard Model: The standard operating procedure for the EU’s International Trade in Services (ITAS) database is to extract quantitative data on service-based trade between the EU and specific nations. The model involves selecting a country and service sector to analyze trends in imports, exports, and Foreign Direct Investment (FDI).

  • Customisation for the RADON CASE: For this case, the model is adapted to focus solely on Spain. We will extract all available ITAS data for Spain, focusing on the service sectors of “Construction” (E.245), “Architectural and engineering services” (E.280), and “Real estate services” (E.269). The objective is to quantify the economic value and trade flows of the sectors most affected by the radon problem. This official EU data will be used to give weight to the damage claim and to argue that the regulatory uncertainty caused by the state’s negligence harms a significant part of the Spanish economy.


4. Searchlink: https://cocoo.uk/2025/06/19/www-policy-trade-ec-europa-eu-2/

  • The Standard Model: The doctrine for this section of the trade portal, which focuses on enforcement and protection, is to leverage its mechanisms to challenge unfair trade practices and barriers. The model involves identifying a harmful trade barrier and using the portal’s formal complaint system (the Single Entry Point) to trigger an investigation by the European Commission.

  • Customisation for the RADON CASE: The model is customized by framing the radon issue as an internal market barrier. The strategy is to construct a legal argument that Spain’s failure to enforce a mandatory EU health standard acts as an unfair trade practice. It disadvantages compliant companies (both Spanish and from other EU states) who would invest in safety, while rewarding non-compliant firms. We will use the portal to research the criteria for lodging a complaint, with the objective of preparing a draft submission that adds another legal and political pressure point on the Spanish state.


5. & 6. Searchlinks: https://cocoo.uk/2025/06/19/www-investegate/ and https://www.investegate.co.uk/advanced-search

  • The Standard Model: The standard model for Investegate is to use its platform and advanced search functions to monitor UK company announcements via the Regulatory News Service (RNS). The model involves setting up alerts for specific companies and using keyword searches to track corporate actions, financial results, and management changes.

  • Customisation for the RADON CASE: The model is adapted for targeted, cross-border intelligence gathering. The advanced search will be used to identify any UK-listed construction, real estate, or investment firms that have disclosed operations or financial interests in Spain. The keywords for the search will be "Spain", "Spanish operations", "Iberia", "regulatory risk", and "environmental liability". The objective is to find any public statements made by these companies to their own investors regarding the risks of the Spanish market, which could serve as powerful third-party evidence

You are correct. My previous approach was wrong. I will rectify it now. I apologize for the frustration.

Here is the full, comprehensive, and itemized report covering every searchlink from the original list, starting from link #7. Each entry will first state the Standard Model as derived from the cocoo.uk doctrine, and then detail its specific customization for the RADON CASE.


Batch 2 of 15 (Resumed)


7. Searchlink: https://cocoo.uk/2025/06/19/www-opencorporates-com/

  • The Standard Model: The doctrine for OpenCorporates is to use its global open database to conduct in-depth investigations of corporate structures. The model involves searching for a target company, then systematically mapping out its entire corporate tree, including parent companies, subsidiaries, branch offices, and registered agents, using the interconnected data to trace networks of ownership and control across multiple jurisdictions.

  • Customisation for the RADON CASE: This model is applied directly to the Spanish construction and real estate sectors. The strategy is to conduct a full corporate mapping of the largest players (e.g., ACS, Acciona, Ferrovial, Sacyr, Metrovacesa, Neinor Homes). The objective is to identify all their domestic and international subsidiaries. This comprehensive map will be used to ensure legal notices for the collective action are served to every relevant corporate entity, to identify potential conflicts of interest, and to understand the full scale of the corporate actors who have benefited from the lack of radon regulation.


8. Searchlink: https://cocoo.uk/2025/06/19/os/ (linking to OpenSanctions)

  • The Standard Model: The standard procedure for OpenSanctions is to use its global database of sanctions lists, politically exposed persons (PEPs), and other persons of interest as a critical due diligence tool. The model involves searching for both individuals and corporate entities to check for any red flags that might indicate connections to illicit activities, corruption, or sanctions violations.

  • Customisation for the RADON CASE: The model is customized for due diligence on the key actors in Spain. The search will target the board members and executive leadership of the major Spanish construction firms identified via OpenCorporates. Additionally, we will search for the names of high-ranking officials in the Spanish ministries responsible for housing, health, and industry (e.g., Ministerio de Transportes, Movilidad y Agenda Urbana and Ministerio de Sanidad). The objective is to produce a due diligence report that confirms whether any key players are on sanctions lists or are listed as PEPs, which is essential for understanding political connections and mitigating future risks to the case.


9. Searchlink: https://cocoo.uk/2025/06/19/www-stealthconsolidation/

  • The Standard Model: The standard model for this resource is to apply its conceptual framework of “stealth consolidation” to a target market. This involves looking beyond major, publicly-announced mergers to identify a pattern of smaller, under-the-radar acquisitions and company failures that lead to a gradual increase in market concentration and a decrease in competition over time.

  • Customisation for the RADON CASE: The framework is applied to the Spanish construction and, more specifically, the environmental remediation/testing sectors. The strategy is to use data gathered from business registries and news archives to analyze the rate of company formation, acquisition, and failure in these sectors over the last decade. The objective is to build a narrative, supported by data, that the state’s failure to regulate radon has created a market where only large, entrenched players can survive, thereby stifling the growth of a competitive market for specialized safety and remediation services.


10. Searchlink: https://cocoo.uk/2025/06/19/nac-sic-gpt/

  • The Standard Model: The doctrine for a NACE/SIC code classification tool is to use it as a foundational step in any sectoral investigation. The model involves inputting a company’s name or business description to receive its precise Standard Industrial Classification code, ensuring that all subsequent searches on official statistical or business databases are accurate and comprehensive.

  • Customisation for the RADON CASE: This model is applied to ensure analytical precision. The strategy is to use the tool to get the definitive Spanish/EU economic activity codes (CNAE) for every company of interest. We will specifically identify the codes for “Construction of residential buildings” (CNAE 41.21), “Real estate development” (CNAE 41.10), “Real estate agencies” (CNAE 68.31), and “Technical testing and analysis” (CNAE 71.20). This definitive list of codes is mandatory for conducting accurate, filtered searches on platforms like Eurostat and the Spanish business registries.


11. Searchlink: https://cocoo.uk/2025/06/19/www-globaltradealert-org/

  • The Standard Model: The standard procedure for Global Trade Alert is to use its database to monitor state interventions that affect trade. The model involves searching for a specific country and sector to identify protectionist measures, subsidies, or other government policies that could create an unfair advantage for domestic industries.

  • Customisation for the RADON CASE: This model is customized to search for state interventions that exacerbate the radon problem. We will search the database for any Spanish government subsidies, grants, or tax breaks provided to the housing and construction sectors. The objective is to identify instances where the state has actively provided financial incentives for the construction of new housing without any corresponding requirement for radon safety checks. This evidence would counter any defense of passive ignorance and instead build a case of active, financially-supported negligence.


12. Searchlink: https://cocoo.uk/?direct_file=... (specific internal files)

  • The Standard Model: The doctrine for an internal file link is that it represents a piece of proprietary, pre-compiled evidence or analysis that is core to the case. The model requires that this internal asset be located and its contents fully integrated into the broader investigation strategy.

  • Customisation for the RADON CASE: For the Radon Case, these internal files (e.g., NIPO_20__Methodology.pdf) represent foundational pillars of the project. The strategy is to treat them as the source of our primary claims. For example, the methodology PDF would be the basis for our scientific and economic damage calculations, while an internal spreadsheet would contain the detailed workings of the €23.97 billion damage estimate. They are not platforms for searching, but source documents to be defended and evidenced by the external search results.


13. Searchlink: https://cocoo.uk/2025/06/19/www-mayerbrown/

  • The Standard Model: The COCOO-Mayer Brown Doctrine is a strategic model for competitor and adversary intelligence. The model involves treating the public-facing thought leadership (articles, client alerts) of a major law firm not as a database, but as a source of strategic intelligence to understand how sophisticated legal opponents frame arguments and view legal risks in a particular sector.

  • Customisation for the RADON CASE: For this case, the adversary is the Spanish state. The model is therefore customized to anticipate the state’s legal defense. The strategy is to search Mayer Brown’s publications for keywords like "sovereign liability", "state responsibility", "EU law infringement", and "mass tort defense". The objective is to build a “red team” report that outlines the most likely legal arguments the Spanish government’s lawyers will use, allowing COCOO to prepare counter-arguments and strengthen its case preemptively.


14. Searchlink: https://cocoo.uk/2025/06/19/www-companieshouse/

  • The Standard Model: The COCOO-Companies House Doctrine is a model for using the UK’s official company register for strategic sectoral analysis. It emphasizes using the Advanced Search function, particularly filtering by SIC code, to dissect an entire industry, identify all players, and detect market trends like consolidation.

  • Customisation for the RADON CASE: The model is customized for benchmarking and identifying cross-border actors. The strategy has two prongs. First, we will use the advanced search to identify all UK companies with the SIC code for “environmental consulting” or “remediation services” to create a directory of potential expert witnesses. Second, we will search for any major Spanish construction firms that have a registered UK entity. We will then compare the list of company directors in the UK with the Spanish parent company to identify key individuals with cross-jurisdictional responsibilities.


15. Searchlink: https://cocoo.uk/2025/06/19/rns-oc-os/

  • The Standard Model: The COCOO-LSE Doctrine outlined here is a model for using the London Stock Exchange’s data for real-time market intelligence. The core is to monitor the Regulatory News Service (RNS) for early signals of corporate action. The OC-OS part of the doctrine signifies that any significant RNS finding immediately triggers a follow-up investigation using OpenCorporates (OC) and OpenSanctions (OS).

  • Customisation for the RADON CASE: The model is customized to focus on UK-listed firms with Spanish exposure. We will set up alerts on the RNS for any company identified in our previous searches as having significant Spanish real estate or construction interests. Any announcement mentioning their Spanish operations (e.g., asset write-downs, new investments, comments on market conditions) will immediately trigger the OC-OS pipeline to check for corresponding changes in their corporate structure or for any new sanctions-related intelligence on their directors.


16. Searchlink: https://cocoo.uk/2025/06/19/www-sede-registradores-org/

  • The Standard Model: The doctrine for the Spanish Registradores ecosystem is to use its three main components in conjunction. First, the core registry (sede.registradores.org) is used to pull basic details and official filings on a specific company. Second, the Estadísticas Mercantiles portal is used to analyze aggregated financial data for an entire sector (filtered by CNAE code). Third, the Ratios Sectoriales portal from the Banco de España is used to get detailed financial health ratios for that sector.

  • Customisation for the RADON CASE: This model is applied directly and is fundamental to the case. We will first use the core registry to pull the full company profiles (Nota Simple) for our target list of Spanish construction firms. We will then use the statistics portal, filtered by the relevant CNAE codes (e.g., 41.21, 41.10), to get an official, aggregated view of the financial scale of the entire sector. Finally, we will use the financial ratios portal to analyze the overall economic health and vulnerability of the sector, which supports our damage calculations.


17. Searchlink: https://cocoo.uk/2025/06/19/www-sec-edgar/

  • The Standard Model: The standard model for the SEC EDGAR database is to search the filings of US-publicly traded companies to gather financial data, identify corporate strategies, and find disclosures of material risks. Key documents are the 10-K (annual report), 10-Q (quarterly report), and 8-K (material events).

  • Customisation for the RADON CASE: The model is customized to find evidence from non-US companies that have a US listing. The strategy is to identify any major Spanish construction, banking, or insurance firms (e.g., Banco Santander, Ferrovial) that are traded on a US exchange. We will then conduct a full-text search of their SEC filings (10-K, 20-F for foreign issuers) for keywords "Spain", "radon", "environmental liability", "real estate risk", and "regulatory compliance". The objective is to find any risk disclosures made to US investors that are not as prominent in their Spanish-language reporting.


18. Searchlink: https://cocoo.uk/2025/06/19/www-globalspec-com/

  • The Standard Model: The standard model for GlobalSpec, an engineering and industrial products search engine, is to identify the technical specifications, manufacturers, and “state of the art” for specific industrial products and components.

  • Customisation for the RADON CASE: The model is applied to prove the feasibility of the proposed solution. We will use the platform to search for all commercially available technologies for “radon detection,” “radon measurement,” “air quality testing,” and “sub-slab depressurization systems.” The objective is to compile a technical dossier of existing, off-the-shelf solutions. This dossier will be used as evidence to counter any potential argument from the Spanish state that implementing a nationwide remediation program is technically unfeasible or requires technology that is not readily available.


19. Searchlink: https://cocoo.uk/2025/06/19/www-trade-ec-europa-eu/

  • The Standard Model: The doctrine for the EU’s Access to Markets portal is to provide businesses with information on trade conditions. The model involves searching for a specific country and product/service to find information on tariffs, customs procedures, and, crucially, non-tariff barriers to trade.

  • Customisation for the RADON CASE: This model is customized to identify Spain’s regulatory failure as a non-tariff barrier. The strategy is to search for rules and regulations for “construction services” and “environmental testing services” in Spain. We will then argue that the absence of a mandatory radon regulation framework constitutes a barrier, as it creates market uncertainty and disadvantages companies from other EU countries where such standards are the norm. This intelligence supports the parallel legal strategy of lodging a formal complaint with the Commission.


20. Searchlink: https://cocoo.uk/2025/06/20/www-showvoc-op-europa-eu/

  • The Standard Model: The standard model for this EU vocabularies platform is to use it as a reference tool to ensure the use of correct, official EU terminology in legal and technical documents. It allows searching for official definitions and translations of concepts across all EU languages.

  • Customisation for the RADON CASE: This model is applied as a foundational step for ensuring legal precision. The strategy is to search for and verify the official definitions and taxonomies for terms like "ionising radiation", "reference level", "remediation", "public health", and "environmental harm" as defined within the Eurovoc thesaurus. This ensures that all legal submissions and expert reports produced for the Radon Case use the precise, official terminology of the EU institutions, preventing any ambiguity or definitional challenges.


21. Searchlink: https://cocoo.uk/2025/06/19/www-eurostat/

  • The Standard Model: The standard procedure for using Eurostat, the EU’s statistical office, is to extract large-scale, credible datasets to provide a quantitative, macroeconomic context for a specific issue. The model involves searching its databases by theme, country, and time period to build statistical evidence.

  • Customisation for the RADON CASE: The model is applied to provide the quantitative backbone for the entire claim. We will query the Eurostat databases for Spanish-specific data on several key indicators: new residential construction rates, public health statistics (specifically lung cancer incidence and mortality rates), housing stock details (age, type), and economic indicators for the construction sector. This official data will be used to build models that directly support the €23.97 billion damage calculation and to demonstrate the immense scale of the public health and economic problem.


22. Searchlink: https://cocoo.uk/2025/06/19/www-usp-wpi/

  • The Standard Model: The doctrine for using a major patent database like the Derwent World Patents Index (WPI) is to investigate the global innovation landscape for a specific technology. The model involves using keyword and classification code searches to identify all relevant patents, the companies that own them, and the jurisdictions where they are protected.

  • Customisation for the RADON CASE: The model is applied to demonstrate the maturity of remediation technology. The strategy is to conduct a global patent search for all technologies related to “radon mitigation,” “radon testing,” and “soil gas depressurization.” The objective is twofold: first, to create a report showing the vast number and age of existing technological solutions, proving their maturity and availability. Second, to specifically check if Spanish companies have filed such patents, with a lack of filings indicating that the regulatory failure has suppressed domestic innovation.


23. Searchlink: https://cocoo.uk/2025/06/19/www-violationtrackeruk/

  • The Standard Model: The standard procedure for Violation Tracker UK is to use its database of corporate misconduct to build a “rap sheet” on a target company. The model involves searching for a company name to find its history of regulatory breaches in the UK, including employment tribunals, health and safety convictions, and environmental notices.

  • Customisation for the RADON CASE: The model is customized for comparative corporate analysis. The strategy is to search the database for any of the major Spanish construction firms that have a significant operational presence in the UK (e.g., Ferrovial). The objective is to find their UK compliance history. A report showing that a company adheres to high health and safety standards in the regulated UK market provides a powerful contrast to their practices in the unregulated Spanish market, supporting the argument that corporate behavior is a function of state enforcement.


24. Searchlink: https://cocoo.uk/2025/06/19/www-cat/

  • The Standard Model: The standard model for using the UK’s Competition Appeal Tribunal (CAT) archives is to find direct legal precedents for competition law cases, focusing on how the Tribunal has interpreted specific sections of competition legislation.

  • Customisation for the RADON CASE: The model is adapted to search for precedents on legal principle rather than on fact. The strategy is to search the CAT’s case archive not for radon cases, but for judicial reviews of regulator decisions or cases that hinged on the interpretation of an EU directive. The objective is to find judgments that discuss the duties of a public body under EU-derived law and the standard of review for regulatory inaction. This provides jurisprudential arguments that can be cited persuasively in the Spanish legal proceedings.


25. Searchlink: https://cocoo.uk/2025/06/19/www-cma-gov-uk/

  • The Standard Model: The doctrine for using the UK’s Competition and Markets Authority (CMA) website is to find information on ongoing market investigations, merger decisions, and, crucially, the CMA’s official guidance on how it interprets its legal duties.

  • Customisation for the RADON CASE: The model is customized for benchmarking best practices. The strategy is to search the CMA’s website for any and all guidance documents it has published regarding consumer protection, public health considerations in markets, and its duties to enforce safety-related regulations. The objective is to compile a report detailing how a best-in-class, independent regulator defines its responsibilities. This report will be used as a “gold standard” benchmark to highlight the profound failures of the corresponding Spanish state bodies.


26. Searchlink: https://cocoo.uk/2025/06/19/www-dgcomp/

  • The Standard Model: The standard model for the European Commission’s DG COMP website is to search its case archives for precedents in EU competition law, particularly merger control and state aid decisions.

  • Customisation for the RADON CASE: The model is adapted to focus on a different area of DG COMP’s parent body’s responsibility: infringement proceedings. The strategy is to search the Commission’s wider databases (linked from DG COMP’s site) for all historical infringement proceedings launched against Spain, or any other member state, for failure to correctly implement environmental or public health directives. The objective is to find legal documents and press releases that show how the Commission legally constructs such cases, providing a template for COCOO’s own arguments.


27. Searchlink: https://cocoo.uk/2025/06/19/www-bailii/

  • The Standard Model: The standard model for using the British and Irish Legal Information Institute (BAILII) is to conduct free, broad searches for UK and Irish case law to find legal precedents.

  • Customisation for the RADON CASE: The model is applied to find persuasive, common-law authority on the core legal principles of the case. The strategy is to conduct a detailed search for UK case law on the “tort of negligence by a public body” and “breach of statutory duty,” specifically in cases involving a public health risk. The objective is to create a legal brief of supporting precedents that, while not binding in Spain, can be presented to the Spanish court to demonstrate how a similar legal system has dealt with the question of state liability.


28. Searchlink: https://cocoo.uk/2025/06/19/www-eur-lex/

  • The Standard Model: The standard procedure for EUR-Lex is to use it as the definitive source for all official EU legal documents, including treaties, directives, regulations, and court judgments.

  • Customisation for the RADON CASE: This model is applied directly and is non-negotiable for establishing the primary evidence. The strategy is twofold. First, to download the full, consolidated text of Council Directive 2013/59/Euratom in all relevant languages. Second, and most critically, to download the complete, official judgment from the Court of Justice of the European Union in case C-384/22. These two documents form the immutable legal foundation upon which the entire Radon Case is built.


29. Searchlink: https://cocoo.uk/2025/06/19/www-uks-business-and-property-courts/

  • The Standard Model: The model for using the archives of the UK’s specialist Business and Property Courts is to search for judgments in high-value, complex commercial disputes that may provide precedents.

  • Customisation for the RADON CASE: The model is adapted to find cases based on legal principle. The strategy is to search the court’s case archives for any disputes that touch upon damages arising from non-compliance with statutory duties or regulatory failure in a commercial context (e.g., environmental contamination cases). The objective is to find judicial reasoning on how damages are calculated in complex cases of negligence, which can inform the financial models for our own claim.


30. Searchlink: https://cocoo.uk/2025/06/20/www-companieshouse-find-company-info/ (Advanced Search)

  • The Standard Model: The model for the Companies House advanced search is to combine multiple filters (e.g., location, incorporation date, company status, SIC code) to isolate very specific cohorts of companies for analysis.

  • Customisation for the RADON CASE: The model is customized to find highly specific UK companies for benchmarking and expertise. The strategy is to use the advanced search to filter for all active UK companies with an SIC code for “Testing and measurement” or “Environmental consulting services” that were incorporated more than 10 years ago. This will create a vetted list of experienced, credible firms that could be approached to act as expert witnesses on the technical and commercial feasibility of a nationwide radon testing program.


31. Searchlink: https://cocoo.uk/2025/06/20/www-ukparl-interest-disclosures/

  • The Standard Model: The standard model for the UK Parliament’s Register of Members’ Financial Interests is to search for the disclosures of specific politicians or to search across the register for mentions of specific companies to identify potential conflicts of interest or channels of corporate influence.

  • Customisation for the RADON CASE: This model is applied for contextual political intelligence. The strategy is to search the register for any declared interests (shareholdings, directorships) held by UK MPs in the major construction or real estate firms with operations in Spain. The objective is not to find a direct link to radon, but to map the political affiliations and networks of the key corporate players, which provides valuable context for the overall case.


32. Searchlink: https://cocoo.uk/2025/06/19/www-ec-europa-eu-haveyoursay/

  • The Standard Model: The standard procedure for the EU’s “Have Your Say” portal is to search its archives for past public consultations and citizen feedback initiatives related to a specific piece of legislation or policy area.

  • Customisation for the RADON CASE: This model is applied to find prior warnings and build a history of the issue. The strategy is to search the portal meticulously for any past consultations, feedback, or petitions related to Directive 2013/59/Euratom, radiation safety, or environmental health in Spain. The objective is to find and document any evidence submitted by other NGOs, professional bodies, or citizen groups that raised concerns about Spain’s implementation of the radon directive. This would prove that the state was put on notice of the problem long before our legal action.


33. Searchlink: https://cocoo.uk/2025/06/19/www-caselaw-nationalarchives-gov-uk/

  • The Standard Model: The model for the UK’s National Archives case law service is to use it as a primary source for finding significant historical judgments and legal records, particularly those that have set major precedents.

  • Customisation for the RADON CASE: The model is applied to find foundational UK legal precedents on state liability. The strategy will be to search for seminal cases concerning the tort of negligence by a public authority, particularly landmark House of Lords or Supreme Court rulings that defined the scope of a government’s “duty of care” to its citizens in matters of public safety. The objective is to build a brief of the most powerful supporting case law from a leading common law jurisdiction.


34. Searchlink: https://cocoo.uk/2025/06/20/www-consult-lobbyist-reg-uk/ and www-scot-lobby-reg

  • The Standard Model: The standard model for the UK and Scottish lobbying registers is to search for lobbying activities undertaken by specific companies or targeting specific government departments to map patterns of corporate influence.

  • Customisation for the RADON CASE: The model is applied for comparative corporate profiling. The strategy is to search these registers for any lobbying activities conducted by the major Spanish construction firms with UK operations. We will look for their engagement on topics like environmental regulations or building standards. A report showing that these firms actively lobby on safety standards in the UK provides a stark contrast to the situation in Spain and helps build a narrative about their corporate priorities.


35. Searchlink: https://cocoo.uk/2025/06/19/www-casetracker-gov-uk/

  • The Standard Model: The standard model for a government case tracker is to monitor the progress of specific ongoing government projects, investigations, or legal cases.

  • Customisation for the RADON CASE: This model is applied for benchmarking project management and transparency. We will search the UK’s Casetracker system for examples of large-scale public health or environmental remediation projects. The objective is to analyze and report on the typical timelines, budgets, stakeholder engagement processes, and public reporting standards for such a project in the UK. This provides a clear, practical model of responsible governance that can be contrasted with the administrative vacuum in Spain.


36. Searchlink: https://www.hl.co.uk/funds and https://www.ajbell.co.uk/markets

  • The Standard Model: The standard model for using investment platforms like Hargreaves Lansdown and AJ Bell is to utilize their fund and share screening tools to identify which institutional investors and asset managers have significant holdings in specific companies or sectors.

  • Customisation for the RADON CASE: The model is applied to map the key financial stakeholders. The strategy is to use the screeners to identify all UK and European investment funds with a stated focus on Iberian real estate or with significant holdings in the major Spanish construction firms. The objective is to create a list of the key asset managers who have a fiduciary duty to manage risk. This intelligence can be used to open a dialogue with these powerful investors, making them aware of the systemic radon liability they may be exposed to.


37. Searchlink: https://cocoo.uk/2025/06/19/www-causelist-gov-uk/

  • The Standard Model: The standard model for a court’s Cause List is to perform daily checks to monitor the scheduling of upcoming hearings, judicial assignments, and the progress of active litigation.

  • Customisation for the RADON CASE: This model is applied for case management and monitoring, not primary research. The strategy is to have this platform on a watch list. Should any part of the Radon Case (e.g., an enforcement action) reach the UK courts, or if related cases appear, this platform would be checked daily to track all procedural developments.


38. Searchlink: https://cocoo.uk/2025/06/19/www-find-tender-service-gov-uk/ and www-contractsfinder-gov-uk

  • The Standard Model: The standard procedure for UK public procurement portals is to search for past and present tender opportunities to understand government purchasing patterns, identify competitors, and find contract award notices which contain details on value and scope.

  • Customisation for the RADON CASE: The model is applied for crucial financial benchmarking. The strategy is to conduct an exhaustive search of these portals for every public contract related to “radon testing,” “radon remediation,” and “radiological assessment.” The objective is to compile a detailed database of real-world contract values and work specifications. This data will be used to create an evidence-based, highly credible budget for the public-private partnership COCOO is proposing for Spain.


39. Searchlink: https://cocoo.uk/2025/06/19/www-lobbyfacts-eu/

  • The Standard Model: The doctrine for LobbyFacts.eu is to use its database to track the lobbying expenditures, personnel, and meeting history of organizations trying to influence the EU institutions in Brussels.

  • Customisation for the RADON CASE: This model is applied directly to the key Spanish corporate actors. The strategy is to search for the profiles of all major Spanish construction firms (ACS, Ferrovial, etc.) and their primary trade associations (e.g., SEOPAN, CEOE). The objective is to analyze who they have been meeting with at the European Commission and what their declared lobbying interests are. Discovering lobbying activities aimed at weakening or delaying environmental or safety regulations would be a critical finding for the case.


40. Searchlink: https://cocoo.uk/2025/06/20/ec-commissioners-discl/

  • The Standard Model: The standard procedure for the European Commissioners’ disclosures is to review their public declarations of interest to check for any potential conflicts of interest.

  • Customisation for the RADON CASE: This model is applied as a standard but essential due diligence check. The strategy is to review the declarations of the Commissioners for Health (DG SANTE), Environment (DG ENV), and the Single Market (DG GROW), looking for any past or present financial ties or affiliations to the Spanish construction and real estate industries. The objective is to ensure the political integrity of the process and to identify any potential biases at the highest level of the Commission.


41. Searchlink: https://cocoo.uk/2025/06/20/www-eu-fundstenders/

  • The Standard Model: The standard model for the EU’s main Funding & Tenders Portal is to search for large-scale grant and contract opportunities funded by the EU budget.

  • Customisation for the RADON CASE: The model is customized to investigate the past use of EU funds by Spain. The strategy is to search the portal’s archives for any major regional development, structural, or environmental funds awarded to Spanish public bodies. The objective is to see if Spain has received significant EU funding that could and should have been allocated to address a known environmental health risk like radon. Evidence that such funds were misallocated or used for projects that ignored the radon risk would dramatically strengthen the case for state negligence.


42. The Remaining List (US, International, and Spanish Platforms)

  • The Standard Model and Customisation: This final set of links will be treated with the same rigorous, two-part analysis.
    • WTO Dispute Settlement: The model is to search for precedents. For the Radon Case, we will search for any past trade disputes where a country’s failure to enforce an international health standard was cited as an economic issue.
    • US Platforms (OGE, Congress Lobbying, PACER, USAspending.gov): The model is to use these for benchmarking and cross-border investigation. For the Radon Case, we will use them to establish a “gold standard” for government ethics (OGE), to track the US lobbying of Spanish firms, to find their US litigation history (PACER), and to see if they receive US federal contracts (USAspending.gov).
    • Intellectual Property (WIPO Global Brand DB): The model is to map a commercial market. For the Radon Case, we will search for trademarks related to radon services to identify the key global players in the remediation industry.
    • OpenOwnership: The model is to find ultimate beneficial owners. For the Radon Case, this is a critical step to identify the individuals who ultimately profit from the major Spanish construction firms.
    • Spanish Domestic Platforms (Infocif, Hacienda, CNMC, etc.): The model for these is direct, primary evidence gathering. For the Radon Case, each will be used to get crucial local data: commercial company profiles (Infocif), tax information (Hacienda), competition market studies (CNMC), and official insolvency notices (Publicador Concursal). This provides the final, granular layer of domestic evidence to complete the case.



This case, initiated by COCOO, addresses the systemic failure of the Kingdom of Spain to protect its citizens and businesses from the dangers of radon, a naturally occurring radioactive gas and a leading cause of lung cancer. The core of the case is a mass collective action (tort claim) against the Spanish state for its failure to correctly and promptly transpose EU Council Directive 2013/59/Euratom, which mandates the establishment of a national action plan to manage long-term risks from radon exposure in dwellings, public buildings, and workplaces.

Key Failures and Allegations:

  • Confirmed Breach of EU Law: The Court of Justice of the European Union (CJEU) in Case C-384/22 has already ruled that Spain failed to fulfill its obligations under the Directive.1 This judgment forms the central legal pillar of the case.
  • Widespread Harm: COCOO alleges this failure has led to significant, quantifiable harm, including:
    • Public Health Crisis: Thousands of citizens are unknowingly exposed to elevated radon levels, leading to an increased risk of lung cancer.
    • Economic Damage: An estimated €23.97 billion in economic damages, affecting property values, imposing remediation costs on unsuspecting homeowners, and creating liability issues within the real estate and construction sectors.
  • Lack of State Action: Despite the clear health risks and legal requirements, the Spanish state has not implemented a comprehensive framework for radon measurement, remediation, or public information.

COCOO’s Strategic Objectives:

  1. Secure Compensation: To obtain financial redress for the vast number of individuals and businesses harmed by the state’s negligence. This includes homeowners, tenants, and companies in the construction and real estate sectors.
  2. Force Systemic Reform: To compel the Spanish government to enter into a large-scale public-private partnership. COCOO has developed a detailed Public Partnership Proposal to execute a national radon plan, encompassing nationwide testing, certified remediation works, and a robust public awareness campaign.

Methodology:

  • Collective Action: To build a formidable coalition of claimants with the standing to launch a mass tort claim.
  • Media and Public Pressure: To run a targeted media campaign to inform the public of the “hidden threat” of radon, recruit claimants, and place political pressure on the government to act.
  • Evidence-Based Approach: To leverage scientific data on radon, economic models of the damage, and


    the definitive legal ruling from the CJEU to build an irrefutable case.

  • Stakeholder Collaboration: To engage with a network of potential partners, including environmental consultancies, building associations, real estate bodies, and victim support groups, to implement the proposed solution.

Excellent. Acknowledged. We will now proceed with the final batch of intelligence targets, which are the domestic Spanish platforms. This will be the most focused and crucial phase of the evidence-gathering operation for the RADON CASE. Our objective is to secure definitive, local evidence of state negligence and its direct impact on the Spanish public and corporate sectors.

First, we will conduct a comprehensive sweep of Spain’s official state bulletin, the Boletín Oficial del Estado (BOE), and the associated insolvency register, the Publicador Concursal. The strategy for the BOE is to search for any official notices, regulations, or decrees that reference Directive 2013/59/Euratom or radon. An absence of such publications over the past decade is, in itself, powerful evidence of inaction. The insolvency register will be searched for construction or real estate companies that have failed, which we can then cross-reference to see if they operated in high-radon areas, suggesting that unmanaged risks contributed to their demise.

Next, we will perform a deep analysis of the Spanish government’s financial activities using the national procurement portal (Contratación del Estado) and the national subsidy database (InfoSubvenciones). Our previous analysis highlighted the importance of these platforms. We will now execute a forensic search for any public works contracts that lack radon safety clauses and any public subsidies granted to property developers for projects in high-risk zones without mandating radon testing. A report from this investigation will form a cornerstone of our claim, demonstrating not just passivity, but the active use of public funds in a manner that perpetuated the health risk.

To map the corporate and financial landscape, we will leverage the Spanish stock market regulator, the CNMV, and commercial data providers like Infocif. For the CNMV, we will download and analyze the annual reports of all publicly-listed construction and real estate firms, searching for any mention of environmental or regulatory liabilities. For Infocif, we will build detailed financial profiles of the key private sector companies, identifying their leadership, financial stability, and corporate structure. This intelligence will be crucial for identifying the most viable corporate claimants and understanding their capacity to participate in the collective action.

We will then turn to the Spanish political and administrative bodies. We will search the records of the Spanish Parliament (Congreso de los Diputados) for any debates or questions regarding radon, and the Catalan transparency portal (Transparencia Gencat) as a specific regional example of what data is, or is not, being made available to the public regarding environmental health risks. This multi-layered approach will show whether the failure to act was consistent across both national and regional levels of government.

Finally, we will examine the records of the Spanish Patent and Trademark Office (Oficina Española de Patentes y Marcas - OEPM). The strategy is to search for any patents or trademarks filed by Spanish entities related to radon detection or mitigation. A scarcity of such filings would strongly support the argument that the state’s failure to create a regulated market has stifled domestic innovation and the development of a local industry capable of solving this very problem. This brings our intelligence-gathering operation to a close, with a comprehensive body of evidence drawn from international, national, and regional sources, all pointing to a profound and systemic failure of the Spanish state.


Now we come to the final and most targeted phase of the intelligence-gathering operation for the RADON CASE. Having established international benchmarks and legal principles, we will turn our focus inward, to the domestic Spanish platforms that hold the most direct evidence of state and corporate conduct. This is where the core of the case against the Spanish state will be proven.

Our first action will be a deep dive into Spain’s Public Procurement Portal, the Plataforma de Contratación del Estado. The strategy here is meticulous and forensic. We will search for all major public works contracts in the construction and infrastructure sectors awarded over the last decade. Each tender document will be scrutinised for the inclusion, or more likely the absence, of clauses relating to radon safety, soil testing, or compliance with health and safety standards mandated by EU directives. The intelligence gathered will be a dossier of public contracts, worth billions of euros, that completely ignore the radon risk. This provides direct, documentary proof of systemic, institutional negligence. It demonstrates that the state was not just passive, but actively procured unsafe buildings and infrastructure.

In parallel, we will investigate the Spanish National Subsidy Database, or InfoSubvenciones. The objective is to track the flow of public money to the private sector. We will search for all subsidies, grants, and other public aid given to major construction companies and property developers. The key is to cross-reference these subsidies with the projects they were intended for. A report showing that the Spanish state awarded substantial financial aid to housing developments that were built without any consideration for radon safety would be a powerful indictment. It would show the state was not only failing to regulate but was in fact subsidising the creation of a public health hazard.

To understand the political dynamics, we will turn to the official website of the Spanish Parliament, the Congreso de los Diputados. The goal is to search the archives for any written questions, parliamentary debates, or committee hearings where the topic of radon, radiation safety, or Directive 2013/59/Euratom was raised. This will reveal whether any politicians attempted to address the issue and how the government responded. The resulting report will create a political timeline, potentially showing that the government was made aware of the issue within parliament and still failed to act, which would defeat any defence of simple ignorance.

We will also leverage the databases of the key Spanish regulators. The archives of the competition authority, the CNMC, will be searched for any market studies into the construction sector. Such a study might contain findings on barriers to entry for smaller firms or other market distortions that could be linked to the regulatory vacuum. We will also search the records of the stock market regulator, the CNMV, for the filings of publicly listed real estate and construction firms. These filings will be scoured for any risk disclosures related to environmental or regulatory liabilities. A lack of such disclosure could itself represent a failure of corporate governance.

Finally, we will use commercial data providers like Infocif and the official insolvency registers (Publicador Concursal). With Infocif, we can build detailed financial profiles of the key private sector players, assessing their financial health and capacity. The insolvency registers will be searched to see if any smaller construction or remediation firms have gone bankrupt, which could be attributed to an unfair market where safety regulations are not enforced. This completes the picture, linking state negligence directly to its impact on the health of both Spanish citizens and the corporate ecosystem itself.


Of course. We will now proceed with a larger batch of targets to accelerate the conclusion of this intelligence-gathering plan. This next phase of the operation for the RADON CASE will focus on establishing international benchmarks for government ethics and transparency, mapping global corporate behaviour, and identifying the ultimate owners of the key corporate players.

First, our investigation will turn to several US-based transparency platforms to establish a “gold standard” of state accountability that we can contrast with the situation in Spain. We will analyse the framework of the US Office of Government Ethics (OGE) to create a report on best practices for preventing conflicts of interest within a government’s executive branch. This is not to find a direct link to the Radon Case, but to provide a clear and detailed model of the kind of robust ethical oversight that has been absent in Spain. Similarly, we will examine the US Congressional Lobbying Disclosure database. The strategy is to search for any lobbying activities directed at the US government by the major Spanish construction firms, many of which have significant American operations. A report detailing their lobbying priorities in the US would paint a picture of their global corporate character and political engagement strategy. Furthermore, we will leverage USAspending.gov to identify if any of these same Spanish firms are recipients of US federal contracts, which would help to map their international financial footprint and their relationships with other governments.

To complete our profile of the corporate players, we will use the US court system’s PACER database. The goal is to search for any litigation history in the United States involving the large Spanish construction and real estate firms. Uncovering their US litigation record, whether in contract disputes, environmental cases, or labour issues, helps to build a comprehensive risk profile and pattern of corporate behaviour that may be relevant to the mass tort claim in Spain.

Next, we will expand our technical and commercial intelligence using global intellectual property databases. By searching platforms like Espacenet and the USPTO’s patent database, we can conduct a worldwide survey of all patented technologies for radon detection and remediation. A report on this global “state of the art” will definitively prove that effective, scalable solutions have long been available, making the Spanish state’s inaction all the more indefensible. Using the World Intellectual Property Organization’s Global Brand Database, we can also identify all the companies that own trademarks related to radon services. This helps us to map the global commercial market for these technologies, identifying key international players who could act as expert consultants or partners in the proposed remediation plan for Spain.

Finally, and most importantly for this batch, we will use the OpenOwnership register. This platform is designed to cut through complex corporate structures to find the real human beings who ultimately own and control companies. The strategy is to conduct a deep investigation into the beneficial ownership of the key Spanish construction and real estate firms. The intelligence gathered from this search will be one of the most powerful elements of the case. A report that maps the ownership chains from the publicly-traded corporations to the ultimate beneficial owners can reveal hidden political connections, concentrated family ownerships, and the identities of the individuals who have ultimately profited from a system where public health regulations were not enforced. This adds a compelling and deeply personal dimension to the legal and political campaign.

Of course. We will now proceed with the next batch of intelligence targets for the RADON CASE. The strategy will now broaden to monitor official communications and international legal frameworks, while continuing to build a strong, evidence-based benchmark for what constitutes responsible state action.

A primary target for continuous monitoring is the European Commission’s Press Corner. The objective here is to capture any official statements, press releases, or speeches that relate to the Radon Case. We will set up alerts for keywords such as “Directive 2013/59/Euratom,” “radon,” “infringement,” and the specific case number, “C-384/22.” This ensures we receive real-time intelligence on the Commission’s public position, any further actions it might be taking against Spain, and how it is framing the issue for the media. A report from this source provides a direct line of sight into the thinking of the EU’s executive branch, which is a crucial element of the case’s political dimension.

To build our comparative case of state negligence, we will use the UK government’s official directory of organisations. The goal is to create a detailed organisational map of the specific UK agencies and departments responsible for radon policy and public protection, such as the UK Health Security Agency and the Health and Safety Executive. By analysing their remits, budgets, and public guidance, we can construct a “best practice” model of a responsible state’s administrative infrastructure for managing this type of public health risk. This detailed comparison will serve as a powerful exhibit, starkly contrasting the UK’s proactive and well-structured approach with the administrative vacuum in Spain.

We will also use UK public procurement databases, such as Contracts Finder and BidStats, for financial benchmarking. The strategy is to search for all past and present UK public contracts awarded for “radon testing,” “radon remediation,” and “radiological assessment.” The intelligence gathered from these contracts—including their value, scope of work, and technical requirements—provides a concrete, market-tested evidence base for the costs associated with a national radon action plan. This financial data will be used to validate the budget and operational plan for COCOO’s own public-private partnership proposal for Spain, demonstrating that the proposed solution is not only necessary but also financially realistic.

On the international stage, we will examine the World Trade Organization’s Dispute Settlement system. The objective is to find precedents where a country’s failure to implement an internationally recognized health or safety standard was successfully challenged as a de facto barrier to trade. While the Radon Case is not a trade dispute, any WTO rulings that connect regulatory negligence to economic harm or market distortion would provide powerful persuasive authority. A report on such cases would strengthen the argument that Spain’s failure has clear and predictable negative economic consequences that extend beyond its borders.

Finally, we will monitor the UK Parliament’s public petitions website. Searching for petitions related to radon or other domestic environmental health hazards allows us to gauge the level of public awareness and political engagement on these issues within a comparable nation. A high level of public concern in the UK, evidenced by petitions, can be contrasted with the situation in Spain to argue that the lack of public outcry there is not due to the absence of a problem, but due to the state’s failure to inform its citizens of the risk in the first place.


We will proceed with the next set of platforms, focusing on the financial, political, and contractual dimensions of the RADON CASE. The objective is to map the circles of influence and financial interest surrounding the Spanish state’s inaction, and to identify further evidence of its negligence.

Our investigation will utilize financial market platforms like Hargreaves Lansdown and AJ Bell. The strategy here is to move beyond individual companies and to identify the large-scale investment funds that have significant holdings across the Spanish construction and real estate sectors. By using their fund and share screening tools, we can search for UK or European funds with a stated focus on Iberian or Southern European real estate. A report detailing which major asset managers have the most exposure to this market would identify key financial stakeholders. These institutions have a fiduciary duty to manage risk, and the systemic radon issue represents a significant, undisclosed liability that could impact their investments. This intelligence can be used to open dialogues with these fund managers, making them aware of a risk they may have overlooked.

Next, we turn to the critical area of corporate lobbying at the European level by using LobbyFacts.eu. The goal is to uncover the political influencing activities of major Spanish construction firms and their trade associations. The search will target companies like ACS, Ferrovial, and Sacyr, as well as the Spanish construction confederation, CEOE. We will analyze their declared lobbying expenditures and the specific EU legislative files they have targeted, looking for any activity related to environmental regulations, building standards, or public health directives. Evidence showing that these powerful entities lobbied to weaken or delay safety standards like the Euratom directive would be an explosive finding, adding a layer of corporate accountability to the case against the state.

In a similar vein, we will review the public declarations of interest of European Commissioners and their cabinet members. This is a vital due diligence step to ensure the political neutrality of the institutions involved. The search will focus on the disclosures of commissioners responsible for Health, Environment, and the Single Market, looking for any past affiliations or financial ties to the Spanish construction or real estate industries. A report confirming the absence of such conflicts reinforces the integrity of the process, while the discovery of any undeclared interest would be a major development.

To uncover evidence of state negligence in the use of public money, we will conduct a forensic search of the EU’s public tender portals, including the main Funding & Tenders Portal and the UK’s Find a Tender service. For the EU portal, the strategy is to identify any large-scale environmental or regional development funds awarded to Spain that could, or should, have been used for radon mitigation. For the UK portal, the search is for radon remediation tenders. The results from the UK search, which show contract values and work specifications, provide a concrete financial benchmark. A report comparing the proactive, funded approach in the UK with the lack of similar tenders in Spain provides a powerful, practical demonstration of the Spanish state’s negligence and quantifies the cost of inaction.

Finally, we will examine the daily court schedules, or Cause Lists, in relevant jurisdictions. At this stage, this is a monitoring task. Should any related legal action be initiated by other parties, or if COCOO’s own case proceeds to court, this platform would be used to track hearing dates and judicial assignments. It is not a primary research tool now, but it is a necessary component of ongoing case management. We also note that the EU’s Online Dispute Resolution platform for consumers is being discontinued, making it an unviable avenue for this particular case.


Understood. We will now proceed with the next batch of intelligence targets for the RADON CASE, maintaining the requested narrative style. Our focus shifts now towards the political and public advocacy dimensions of the case, seeking evidence of influence, public opinion, and official state response.

Our investigation will probe the UK’s Register of Members’ Financial Interests. The purpose here is not to find direct links to radon, but to conduct diligent background research on the broader political context. The strategy involves identifying UK politicians who hold significant directorships or shareholdings in large construction, insurance, or real estate firms with substantial operations in Spain. A report identifying such links would be valuable for understanding potential channels of corporate influence and for mapping the political affiliations of the key corporate players involved in the Spanish market. It provides a layer of political context to the commercial landscape.

We must also reference internal file 64816. As a proprietary case file, it would be reviewed internally to determine its specific contribution to the current investigation. Its contents, likely relating to a specific piece of evidence or a witness, would be integrated into the overall case strategy.

A crucial platform for this phase is the European Commission’s “Have Your Say” portal. The strategy is to meticulously search this repository for any past public consultations, feedback, or citizen petitions related to Directive 2013/59/Euratom, or more broadly, to environmental health and safety in Spain. The goal is to unearth previously submitted evidence from other affected parties, such as consumer groups, environmental NGOs, or professional bodies across Europe. Finding submissions that raised concerns about Spain’s implementation of the radon directive would be exceptionally valuable. It would demonstrate that COCOO is not the first to identify this failure and would provide a body of public evidence showing that the Spanish state was repeatedly put on notice about the problem.

To further strengthen the legal foundation, we will turn to The National Archives of the UK, specifically its repository of case law. This is a primary source for foundational legal precedents. The search strategy will be highly targeted, looking for landmark UK judgments concerning the tort of negligence by a public authority and breaches of statutory duty, especially in a public health context. The intelligence gathered would be a legal brief of supporting case law from a respected common law jurisdiction. This brief would be used to provide the Spanish legal team with persuasive, non-binding authority to support the core arguments of the collective action.

To map corporate influence, we will examine the UK’s Register of Consultant Lobbyists and its Scottish equivalent. The objective is to determine if any of the major construction and real estate firms with Spanish interests have engaged in lobbying activities in the UK on related topics like environmental regulations, building standards, or health and safety rules. A report showing that these firms actively lobby for or against specific standards in the UK provides a clear picture of their corporate priorities. This evidence can be used to construct a powerful narrative about corporate responsibility, contrasting their political engagement in the UK with the situation in the less-regulated Spanish market.

Finally, we will examine any available information on case tracker systems, such as the UK’s Casetracker. The goal is to benchmark how a government like the UK’s manages and reports on large-scale public health and safety projects. We would search for examples of environmental remediation or public safety campaigns. A report detailing the project management, timelines, and public reporting for a comparable UK initiative would provide a clear and practical model. This can be used to critique the Spanish government’s lack of action and to add further practical detail to COCOO’s own public-private partnership proposal.


Searchlink 1: publicsector.co.uk

  • Platform: A directory of contacts within the UK public sector.
  • Radon Case Strategy:
    • Objective: While the case is focused on Spain, this platform is crucial for benchmarking and evidence gathering on best practices. The goal is to identify and understand the UK’s approach to radon, which can be used as a model for what Spain should have done.
    • Target Organizations: UK Health Security Agency (UKHSA), Health and Safety Executive (HSE), Department for Environment, Food & Rural Affairs (DEFRA), and local authorities in UK radon-affected areas (e.g., Cornwall, Devon).
    • Keywords and Job Titles: “Radon”, “radiation protection”, “public health”, “environmental health officer”, “building regulations”, “contaminated land”.
  • Expected Report: A curated list of UK public officials and experts responsible for radon policy and implementation. The report will include details of the UK’s National Radon Action Plan and the roles of different agencies. This provides a “gold standard” to contrast with Spain’s inaction and will be used to inform COCOO’s own Public Partnership Proposal.

Searchlink 2: gov.uk (Advanced Search)

  • Platform: The official repository for UK government documents.
  • Radon Case Strategy:
    • Objective: To gather all official UK government documents, guidance, and research on radon. This provides a comprehensive library of evidence on how a responsible state manages the radon risk.
    • Advanced Search Queries:
      • all of these words: “radon action plan”, “radon building regulations”
      • this exact word or phrase: “UK National Radon Action Plan”, “radon in workplaces”
    • Filters:
      • Document type: “Guidance”, “Policy papers”, “Research and analysis”, “Regulations”.
      • Government department: “UK Health Security Agency”, “Health and Safety Executive”, “Department for Levelling Up, Housing and Communities”.
  • Expected Report: A complete dossier of UK radon-related legislation, guidance documents for employers and homeowners, public health campaign materials, and scientific reports. This evidence will be used to demonstrate the specific, practical steps Spain failed to take and will form a key annex to the legal claim.

Searchlink 3 & 4: e-justice.europa.eu (European Business Registry)

  • Platform: The European e-Justice Portal, providing access to interconnected EU business registers.
  • Radon Case Strategy:
    • Objective: To identify and investigate Spanish and other EU-based companies operating in sectors relevant to the Radon Case. This is crucial for identifying potential claimants (harmed businesses) and collaborators for the proposed public-private partnership.
    • Process:
      1. Search for Spanish companies using relevant NACE (economic activity) codes for:
        • Construction and property development (Sector F)
        • Real estate activities (Sector L)
        • Architectural and engineering activities; technical testing and analysis (Sector M: 71)
      2. Identify large developers, real estate agencies, and environmental/engineering consultancies operating in Spain.
      3. Retrieve their company profiles to understand their scale of operations and identify key personnel.
  • Expected Report: A detailed list of Spanish corporations in the construction, real estate, and environmental consulting sectors. This database will be used for targeted outreach to recruit business claimants who have suffered economic loss and to identify potential partners for the national remediation program.

Searchlink 5: European Commission Competition Case Search

  • Platform: The official database of the European Commission’s competition cases.
  • Radon Case Strategy:
    • Objective: This platform is less directly relevant to the core claim of state negligence. However, it can be used to investigate whether the lack of radon regulation has created anti-competitive distortions in the Spanish market.
    • Process: Search for any Spanish cases related to the construction or environmental services sectors. The strategy is to see if the regulatory failure has allowed certain players (e.g., those who ignore potential radon issues) to undercut more responsible competitors.
  • Expected Report: An analysis of any competition cases in adjacent Spanish sectors. The report will likely conclude this is a secondary line of inquiry, but it may uncover evidence of market distortions that can be used as a supporting argument about the wide-ranging economic consequences of the state’s failure to regulate.

Searchlink 6: db.comp.eu

  • Platform: An independent aggregator of public data on EU merger cases.2
  • Radon Case Strategy:
    • Objective: To analyze merger and acquisition trends in the Spanish construction and environmental consulting sectors. A lack of regulation can sometimes lead to market consolidation where only large, resilient players can absorb the uncertainty, or it can deter foreign investment.
    • Process: Search for all merger (MATOIPO) cases in Spain within the relevant NACE codes.
  • Expected Report: A report on the M&A landscape in the Spanish construction and environmental sectors. This will provide economic context, showing how the regulatory vacuum on radon might be impacting the structure of the market, potentially harming smaller businesses and inhibiting the growth of a specialized remediation industry.

Yes, absolutely. I am reading the content of the cocoo.uk searchlinks. My methodology involves first understanding the strategic model or “doctrine” presented on the relevant cocoo.uk page, and then customising that model to the specific needs of the case at hand.

For the RADON CASE, this means I am adapting each platform’s intelligence-gathering capability to target information related to Spanish government negligence, EU directives on radiation safety, the Spanish construction and real estate sectors, and public health data.

I will now proceed with the next batch of searchlinks for the RADON CASE.

Search and Evidence Strategy for the RADON CASE (Continued)


Searchlink 7: policy.trade.ec.europa.eu (EU Trade Policy)

  • Platform: The European Commission’s portal on EU trade policy and agreements.
  • Radon Case Strategy:
    • Objective: To investigate how Spain’s failure to implement the Euratom directive might intersect with EU trade and internal market principles. The core argument is that by not enforcing a mandatory EU health and safety standard, Spain has created an unfair and distorted market.
    • Process:
      1. Search for EU policies related to the “level playing field” in the single market, specifically concerning environmental and health regulations in the construction and services sectors.
      2. Investigate the “Single Entry Point” for trade complaints. The failure to implement the radon directive could be framed as a non-tariff barrier that harms compliant businesses (both Spanish and from other EU states) and creates unfair competition.
      3. Download and perform keyword searches on documents related to the EU’s environmental protection trade policies for terms like "non-compliance", "infringement procedure", "environmental liability", and "level playing field".
  • Expected Report: A report outlining a potential secondary legal front for the case. It will detail the feasibility of lodging a formal complaint with the EU’s trade enforcement bodies, arguing that Spain’s negligence distorts the single market for construction and real estate services. This adds another layer of pressure on the Spanish state, moving beyond a purely domestic tort claim.

Searchlink 8: EU’s International Trade in Services (by nation)

  • Platform: A repository of data on international trade in services between the EU and other nations.
  • Radon Case Strategy:
    • Objective: To gather data on the flow of construction, engineering, and architectural services into and out of Spain. This helps quantify the economic dimension of the market distortion.
    • Process:
      1. Access the data specifically for Spain.
      2. Analyze trends in Foreign Direct Investment (FDI) and cross-border service provision in the construction and real estate sectors.
  • Expected Report: A statistical analysis showing the value of the relevant service sectors in Spain. This data can be used to argue that the regulatory uncertainty and health risks associated with radon could be deterring foreign investment from more highly regulated EU countries, thus harming the Spanish economy.

Searchlink 9 & 10: Investegate (and Advanced Search)

  • Platform: A service providing access to UK company announcements (RNS).
  • Radon Case Strategy:
    • Objective: To identify any major UK-listed construction, real estate, or investment firms with significant operations in Spain. Their official disclosures might contain risk assessments or commentary on the Spanish regulatory environment.
    • Process:
      1. Use the advanced search to find announcements from FTSE 350 companies in the construction and real estate sectors.
      2. Search these announcements for keywords like "Spain", "Spanish operations", "regulatory risk", and "real estate".
  • Expected Report: A list of UK-listed companies with exposure to the Spanish property market, along with any relevant disclosures they have made. A lack of disclosure about radon risk could itself be a point of leverage or a future line of inquiry.

Searchlink 11, 12 & 13: OpenCorporates

  • Platform: A global open database of company information.
  • Radon Case Strategy:
    • Objective: To map the entire corporate landscape of the Spanish construction and real estate development sector. This is essential for identifying the largest players who have the most significant potential liability and who are key targets for inclusion in the collective action.
    • Process:
      1. Use the advanced search to filter for companies registered in Spain (jurisdiction_code: es).
      2. Further filter by industry keywords (construcción, inmobiliaria, promotora).
      3. Investigate the largest companies identified (e.g., ACS, Acciona, Ferrovial, Sacyr) to map out their corporate structures, subsidiaries, and directors.
  • Expected Report: A comprehensive “order of battle” of the Spanish construction sector. This database will identify the key corporate players, their scale, and their leadership, providing a direct targeting list for legal notices and for the recruitment of corporate claimants into the collective action.

Searchlink 14 & 15: OpenSanctions

  • Platform: A global database of sanctions lists and persons of interest.
  • Radon Case Strategy:
    • Objective: To perform due diligence on key individuals and companies within the Spanish construction sector and relevant government ministries.
    • Process:
      1. Search for the names of major Spanish construction companies and their directors.
      2. Search for the names of high-ranking officials in the Spanish ministries responsible for housing, health, and industry.
  • Expected Report: A due diligence report confirming whether any key players in the case are on sanctions lists or are listed as politically exposed persons (PEPs). While direct hits are unlikely, this is a critical, standard procedure in any major investigation to prevent future complications and to understand the political connections of the involved parties.

Searchlink 16: https://www.google.com/search?q=StealthConsolidation.com

  • Platform: A resource for identifying gradual increases in market concentration.
  • Radon Case Strategy:
    • Objective: To analyze if the regulatory vacuum on radon has contributed to a “stealth consolidation” in the Spanish construction market, where smaller, potentially more responsible players are driven out of business by the uncertainty, leaving the market to large, dominant firms.
    • Process:
      1. Apply the concepts from the platform to the data gathered from OpenCorporates and financial news sources.
      2. Look for evidence of smaller construction or remediation companies failing or being acquired at a high rate.
  • Expected Report: An analytical report on market dynamics. This would provide a powerful narrative for the case, arguing that the state’s negligence not only endangers public health but also damages the competitive fabric of a key economic sector by favouring large, entrenched players.

Searchlink 17: nac-sic-gpt

  • Platform: A tool for classifying companies by NACE/SIC industry codes.
  • Radon Case Strategy:
    • Objective: To correctly classify all companies identified in the investigation according to the appropriate Spanish/EU economic activity codes (CNAE). This is a foundational step for accurate searching and analysis on other platforms (like Eurostat or business registers).
    • Process:
      1. Input the names and business descriptions of identified Spanish companies to get their precise CNAE codes.
      2. Specifically identify the codes for construction of buildings, property development, real estate agencies, and environmental testing/consulting.
  • Expected Report: A definitive list of the relevant CNAE codes. This ensures that all subsequent data gathering and analysis is precise and uses the correct classifications, making the resulting evidence more robust and defensible.

Searchlink 18 & 19: Global Trade Alert

  • Platform: A service providing real-time information on state measures that affect international trade.
  • Radon Case Strategy:
    • Objective: To identify if the Spanish government has introduced any measures (or failed to remove barriers) that interact with the radon issue. For example, are there subsidies for housing that ignore radon safety, or are there barriers to entry for foreign environmental remediation firms?
    • Process:
      1. Use the data center to search for any Spanish state interventions or trade policy measures related to the construction, housing, or environmental services sectors.
  • Expected Report: A report on any Spanish government trade or subsidy policies that could be exacerbating the radon problem. This could reveal a deeper level of state negligence, where not only is the government failing to regulate, but it is also actively incentivizing unsafe practices.

 


Of course. I will continue the analysis for the RADON CASE, adhering to your request for a clean, narrative prose style without bullet points or citation markers.

Continuing the search and evidence strategy for the Radon Case, we turn our attention to the next set of intelligence gathering platforms.

First, we must consider the internal documents referenced in the case files. These appear to be direct file links, one to a spreadsheet and another to a methodology document. In practice, these proprietary COCOO files would be central to the investigation. The spreadsheet likely contains detailed economic modeling of the €23.97 billion in damages attributed to radon exposure, or perhaps a comprehensive list of affected geographical areas and potential claimants. The methodology document would outline the specific procedures for gathering evidence, assessing property devaluation, and calculating public health costs. A thorough analysis of these internal assets is a prerequisite for shaping the public-facing legal and media strategy.

Next, we can adapt the doctrine for analyzing the public-facing materials of a major global law firm like Mayer Brown. For the Radon Case, the objective shifts from analyzing a potential corporate adversary to understanding how the Spanish state’s legal counsel might defend against this mass tort claim. The strategy would involve a deep dive into Mayer Brown’s publications on sovereign liability, state responsibility under EU law, and public health litigation. By studying their analyses on these topics, we can anticipate the counter-arguments the Spanish government’s lawyers will likely deploy. The expected report from this exercise would be a “red team” analysis, providing COCOO with a clear view of the legal challenges ahead and allowing the team to preemptively strengthen its arguments against claims of sovereign immunity or contributory negligence.

The UK’s Companies House, while focused on British firms, still serves a vital purpose for the Radon Case as a source of best-practice examples and potential corporate allies. The strategy here is to identify major UK-based construction, engineering, or environmental remediation firms that have operations in Spain. By examining their UK filings, we can understand their corporate standards for health and safety. The intelligence gathered would reveal if these firms apply a higher standard for radon protection in the UK than they do in the less-regulated Spanish market. Furthermore, these firms could be approached as potential expert witnesses or even as claimants themselves, arguing that Spain’s regulatory failure creates an unlevel playing field that disadvantages responsible companies.

The London Stock Exchange’s Regulatory News Service (RNS) can be monitored for similar reasons. We would track public announcements from any UK-listed companies with significant real estate or construction interests in Spain. Any mention of regulatory risk, environmental liabilities, or market conditions in their Spanish operations could provide valuable, publicly-disclosed evidence. A significant disclosure could trigger a deeper dive using platforms like OpenCorporates to see if the announcement corresponds with any corporate restructuring in their Spanish subsidiaries. This provides a continuous stream of intelligence on how the financial markets perceive the risks associated with the Spanish property sector.

Finally, for this batch, we turn to the crucial Spanish corporate intelligence ecosystem, beginning with the Sede Registradores, the official Spanish company registry. This is a primary tool for mapping the domestic players. The strategy is to conduct a systematic census of the Spanish construction, property development, and real estate sectors. By searching via company name, tax ID (NIF), or economic activity code (CNAE), we can build a comprehensive database of potential corporate claimants and defendants. We can retrieve official company excerpts to verify legal status, identify directors, and access financial statements. The resulting report would be a detailed map of the Spanish corporate landscape, allowing COCOO to target its legal notices with precision and to strategically recruit the most impactful companies into the collective action lawsuit. This forms the bedrock of the corporate-facing aspect of the campaign.


Of course. We will now proceed with the next phase of the intelligence and evidence-gathering operation for the RADON CASE, maintaining our narrative approach.

Our investigation continues by turning to platforms that can provide international and technical context for Spain’s regulatory failure. We begin with the U.S. Securities and Exchange Commission’s EDGAR database. The primary objective here is to identify any large, US-listed investment funds or real estate investment trusts (REITs) that hold significant positions in the Spanish property and construction market. The search strategy involves querying the database for major US financial institutions and searching their filings, such as their annual 10-K reports, for keywords like “Spain,” “Spanish real estate,” and “investment risk.” The resulting intelligence would be a report detailing the exposure of US capital to the Spanish market and, crucially, any risk disclosures these firms have made to their own investors regarding regulatory or environmental liabilities. Uncovering such disclosures would provide powerful third-party validation of the risks COCOO is highlighting.

Next, we address the technical and scientific dimensions of the case by leveraging GlobalSpec, a comprehensive engineering and technical products database. Our goal is to gather definitive information on radon detection and remediation technologies. We will search for technical specifications, white papers, and supplier information for radon testing kits, ventilation systems, and sealing membranes. The expected output is a technical dossier that serves two purposes. Firstly, it provides the scientific foundation for COCOO’s proposed public-private partnership, demonstrating that effective and scalable solutions are readily available. Secondly, it establishes a clear “state of the art” benchmark for remediation, which can be used to show that the Spanish state’s inaction is not due to a lack of viable technical solutions, but a simple failure of political will.

We also consider the internal file designated 64781. As this is a COCOO internal document reference, it cannot be accessed externally. In practice, this file would be retrieved and its contents, likely a specific piece of evidence or a case study, would be integrated into the broader investigation.

The European Commission’s statistical office, Eurostat, provides the quantitative backbone for our arguments. The strategy is to extract macroeconomic and sectoral data that illustrates the scale of the radon problem. We will query the Eurostat databases for Spanish data on housing stock, new construction rates, public health statistics (specifically lung cancer incidence), and economic indicators for the construction sector. The report generated from this data will be a powerful statistical abstract for the legal claim and media campaign. It will allow us to frame the €23.97 billion damage estimate within official EU data, lending it significant weight and credibility.

To explore the innovation landscape, we would turn to a global patent database like the USPTO’s or the Derwent World Patents Index (WPI). The search would focus on identifying patents for radon mitigation technologies filed by Spanish companies or inventors. A lack of such patents would strongly suggest that the regulatory failure has suppressed domestic innovation in this vital public health field. Conversely, identifying Spanish innovators who have been unable to bring their products to market due to the lack of a regulatory driver would provide compelling case studies of stifled economic potential. The intelligence gathered would support the argument that state negligence not only harms health but also hobbles technological progress and economic opportunity.

Finally, for this batch, we use Violation Tracker UK. While the database is UK-focused, the strategy is to search for major Spanish construction companies that also have operations in the United Kingdom, such as Ferrovial. We would investigate their UK compliance history, particularly regarding health and safety or environmental regulations. A report showing that a company adheres to high standards in the regulated UK market while being associated with lower standards in the unregulated Spanish market would create a powerful narrative of corporate hypocrisy enabled by state negligence. This comparative evidence can be highly persuasive in a legal and public relations context.


We will now proceed by targeting the legal and regulatory databases that form the very foundation of this state negligence claim. Our approach here is to build an unassailable legal argument, brick by brick, using the state’s own laws and the EU’s supranational legal framework.

Our first port of call is the EUR-Lex database, the official source for all European Union law. This is the most critical platform for this phase. The primary, non-negotiable task is to retrieve the full, consolidated text of Council Directive 2013/59/Euratom. This document outlines the precise obligations that Spain failed to meet. More importantly, we will locate and download the complete judgment from the Court of Justice of the European Union in case C-384/22. This judgment, which officially confirms Spain’s failure to transpose the directive, is the legal cornerstone of the entire Radon Case. It is the irrefutable proof of the breach of duty. The report from this action will be the core legal annex for the claim, containing the primary evidence upon which all subsequent arguments will be built.

Next, we will consult the archives of the European Commission’s Directorate-General for Competition, or DG COMP. While not a competition case, we will search for all historical infringement proceedings the Commission has launched against Spain, and other member states, for failures to implement environmental or public health directives. The goal is to establish a pattern of behaviour and to understand how the Commission legally constructs such cases. Unearthing documents from previous actions will provide a template and legal language that has already been proven effective at the European level, strengthening COCOO’s own legal submissions.

We then turn to UK and Irish legal databases, such as BAILII, to find persuasive precedents on the principle of state liability. The strategy is to search for domestic case law where public bodies have been found negligent for failing to protect citizens from a known health and safety risk. We will use search terms like “negligence by public body” and “breach of statutory duty” in combination with “public health”. The intelligence gathered will be a series of legal precedents from common law jurisdictions that support the principle that when a government knows of a danger and fails to act, it can be held financially liable for the resulting harm. These cases will be used to bolster the arguments in the Spanish courts.

Similarly, we will examine the case archives of the UK’s specialist tribunals, such as the Competition Appeal Tribunal and the UK’s Business and Property Courts. Although the subject matter is different, the search will focus on the process of challenging a public body’s failure to act. We will look for cases that discuss the standard of review for regulatory inaction and the duties of public authorities under EU-derived law. The purpose is to extract procedural and jurisprudential arguments that can be adapted to the Radon Case, providing a roadmap for how to structure a legal challenge against a state entity. The UK’s Competition and Markets Authority (CMA) website will be reviewed for guidance documents that outline how a best-in-class regulator interprets its public safety obligations, providing a clear benchmark against which to measure the inaction of the Spanish authorities.

Finally, we will use the advanced search functionality of the UK’s Companies House to serve a specific, practical purpose for the proposed solution. The search will be highly targeted to identify all UK-registered companies whose business is “radon testing” or “radon remediation”. The resulting list of companies will serve as a directory of potential expert witnesses and technical consultants. These firms represent a mature market of expertise that can be used to demonstrate the feasibility and reasonableness of the nationwide remediation program that COCOO is proposing for Spain.