PROYECTO DE CONTRATACION PUBLICA : EU BUDGET

 SOLICITUD DE PARTICIPACION       [ media campaign]   [ communicaciones ]

Recent SRB Tenders Search on TED and PCSP

I searched TED (Tenders Electronic Daily, the EU’s official portal) for SRB tenders in 2025 (focusing on open procedures >€140k, relevant to our themes like ICT/security/compliance). Results show several active/ongoing notices since January 2025, emphasizing digital/ICT services—opportunities for our Spanish consortium strategy (e.g., auditing via PCSP-tied EU funds). No direct SRB hits on PCSP (contrataciondelestado.es); results reference unrelated Spanish local entities (e.g., Madrid’s IMTP/SRB dept.), confirming SRB tenders are EU-centralized on TED.

Actionable Insights:

4+ active in H1 2025; download full specs from TED for bidding (form ROLECE-registered Spanish partner ASAP). No PCSP overlap—focus EU pivot.

SPANISH TENDERS RELATED TO THIS CASE

EU TENDERS RELATED TO THIS CASE

This plan executes the two-track strategy for each of the five sub-cases.

Phase 1: Foundation & Mobilisation (Current Phase – Months 1-3)

Track 1: Legal & Public Affairs

• Step 1: Launch and Promote the Claimant Recruitment Campaign.
  • Action: Drive traffic to the eubudget.cocoo.uk compensation campaign page through targeted digital outreach and press releases.
  • Case-Specific Focus:
    • EC: Target EU-wide taxpayer associations, highlighting the alleged €25 million in damages from failed supervision.
    • ELA: Reach out to European professional training and event management associations, showing how members were harmed by irregular contracts.
    • CPVO: Contact IT security and consultancy firms, explaining they were likely excluded due to alleged contract splitting.
    • SRB: Engage with banking and financial services federations, highlighting the risk from the alleged lack of a control framework and unequal treatment.
    • EEA: Connect with environmental NGOs and EU grant recipients who may have faced funding uncertainties.
• Step 2: Consolidate Evidence and Prepare Legal Arguments.
  • Action: Systematically collate all information received from parties joining the campaign via the website. Draft the five specific Letters Before Claim.
  • Purpose: To build a robust evidence file for each sub-case and prepare for formal legal action.

Track 2: Commercial & Policy Proposal

• Step 1: Monitor Procurement Portals for Specific Keywords.
  • Action: Set up alerts on the TED portal for keywords directly related to the case failures.
  • Case-Specific Focus:
    • EC: “Financial oversight,” “VFM,” “public accountability framework.”
    • ELA: “Procurement audit,” “training evaluation,” “compliance checks.”
    • CPVO: “IT procurement,” “cybersecurity audit,” “fair competition.”
    • SRB: “Financial risk management,” “banking regulation,” “control framework.”
    • EEA: “Grant management oversight,” “environmental project audit.”
• Step 2: Refine the POPIA Framework Proposal for Each Agency.
  • Action: Create five tailored versions of your Unsolicited Proposal (USP).
  • Case-Specific Focus:
    • For the EC: Frame POPIA as a solution to its systemic oversight failures.
    • For the ELA: Frame POPIA as a tool to prevent irregular payments and ensure budgetary annuality.
    • For the CPVO: Frame POPIA as a mechanism to enforce transparent tendering.
    • For the SRB: Frame POPIA as a ready-made control framework to manage the Single Resolution Fund.
    • For the EEA: Frame POPIA as a system to ensure robust oversight of outsourced financial checks.

Phase 2: Engagement & Pressure (Months 4-6)

Track 1: Legal & Public Affairs

• Step 1: Issue Formal Legal Notices.
  • Action: Send the five finalised Letters Before Claim to the respective legal departments of the EC, ELA, CPVO, SRB, and EEA.
  • Purpose: To formally initiate the pre-litigation process under Articles 265 and 340 TFEU.
• Step 2: Targeted Political & Media Engagement.
  • Action: Send tailored briefing notes to the EU budgetary control committees and relevant media.
  • Case-Specific Focus:
    • Brief the CONT committee on the overall €48 million+ alleged mismanagement across all five cases.
    • Pitch a story to financial journalists about the SRB’s alleged €15 million risk.
    • Pitch a story to IT trade press about the CPVO’s alleged anti-competitive practices.

Track 2: Commercial & Policy Proposal

• Step 1: Identify and Select a Specific Tender Opportunity.
  • Action: Based on monitoring, select the single most relevant tender to pursue.
  • Purpose: To focus resources on a winnable contract.
• Step 2: Develop the Below-Threshold Proposal.
  • Action: If no suitable tender is found, finalise the sub-£10,000 “scoping study” proposal.
  • Case-Specific Focus: Propose a £9,500 study for the CPVO to “independently review its IT procurement procedures to prevent future contract splitting and ensure compliance with Article 160 of the Financial Regulation.” This is a tangible, low-risk offer that directly addresses their specific alleged failure.

Relevant Tender Opportunities

Identifying currently open tenders with future deadlines is challenging without live portal access. My searches identify the types of tenders that are frequently issued and for which you should be constantly monitoring. The following is a recent, highly relevant example that serves as a perfect model for what to look for.

Exemplary Tender Opportunity:

• Tender Title: Framework contract for the provision of evaluation, impact assessment, and related services for the European Commission
• Contracting Authority: European Commission (Secretariat-General)
• Reference (Example from a past cycle): 2023/S 097-299381 (Note: This is an example of a recurring tender. New cycles are frequently announced).
• Subject Matter: The Commission seeks external experts to provide services across multiple lots, including:
  • Lot 1: Evaluation and Impact Assessment: Assessing the performance, effectiveness, and value-for-money of EU policies and programmes.
  • Lot 3: Institutional and Horizontal Support: Providing expertise on governance, accountability, and performance frameworks for public bodies.
• Time Limits: These large framework contracts are typically re-tendered every 2-4 years. While the deadline for a specific cycle may have passed, a new call is often in the pipeline. You must monitor the TED portal for a new “Contract Notice” or “Prior Information Notice” for “evaluation services” from the European Commission.

Relevance to Your EUBUDGET Cases:

• This single framework contract is relevant to all five of your sub-cases, particularly the primary case against the European Commission for its failure of supervision.
• How you could apply:
  • You would form a consortium with established partners (as per our strategy) to bid for Lot 3 (Institutional Support).
  • Your bid’s central theme would be the POPIA Framework as an innovative solution to the very problems of governance and accountability this tender seeks to address.
  • You would use your detailed findings from the ELA, CPVO, SRB, and EEA cases as evidence of your unique insight into the systemic weaknesses that the Commission needs to fix.

Actionable Advice:

1. Focus on Framework Contracts: Do not just look for small, specific projects. Your best route to market is to get onto a large, multi-year Framework Contract like the one described above. This positions you as a pre-approved expert supplier.
2. Monitor TED Daily: You or a team member must check the TED portal daily for new notices from your five target institutions.
3. Prepare a Consortium: Your immediate commercial priority should be to finalise discussions with one or two potential partner firms who have experience winning EU framework contracts. You cannot wait until a tender is published; you must be ready to move immediately when it is

Call to Action

COCOO believes this Unsolicited Project Proposal offers a unique and invaluable opportunity for the European Commission to pioneer a new standard in public accountability and financial stewardship. We are confident that the POPIA Framework will deliver transformative improvements.

We formally request a meeting with the relevant Commissioners and Directorate-Generals at your earliest convenience to present this proposal in further detail and discuss a collaborative path forward

Unsolicited Project Proposal

To: The President of the European Commission & The College of Commissioners European Commission Brussels, Belgium

From: The Competition & Consumer Organisation Party Limited (COCOO) 23 Village Way, Beckenham, BR3 3NA, United Kingdom UK Companies House Registration Number: 15466919 Email: contact@cocoo.uk

Date: June 1, 2025

Subject: Unsolicited Project Proposal: Establishing a Proactive Oversight, Value for Money (VFM), and Public Interest Assurance Framework for EU Agencies and Financial Management

1. Introduction: The Urgent Need for Enhanced Accountability

The Competition & Consumer Organisation Party Limited (COCOO), an entity committed to enforcing competition law, safeguarding consumer welfare, and protecting the public interest, submits this Unsolicited Project Proposal (USP) to the European Commission (EC). This proposal directly addresses critical and documented deficiencies in the EC’s oversight of EU agencies and the management of EU funds, which have led to significant financial mismanagement, procurement irregularities, and a tangible erosion of public trust and the Union’s “Non-Visible Wealth.”

COCOO has already served the European Commission with a Formal Notice of Failure to Act (Article 265 TFEU) and a Claim for Damages (Article 340 TFEU) on January 13, 2025, detailing these concerns. This proposal offers a constructive and urgent pathway to rectify these systemic issues, leveraging COCOO’s unique expertise, evidence base, and strategic approach to ensure genuine accountability and deliver lasting public value. We believe this collaborative approach can achieve more rapid and effective remediation than protracted litigation, although COCOO remains fully prepared to pursue all legal avenues to protect the public interest.

2. Problem Statement: Systemic Failures in EC Oversight and their Detrimental Impact

The European Commission’s paramount duty to ensure sound financial management (Articles 317 & 318 TFEU) and adherence to procurement regulations (e.g., Regulation (EU, Euratom) 2018/1046) across its agencies has demonstrably faltered. This is evidenced by:

• Recurrent Audit Findings: The European Court of Auditors (ECA) has repeatedly highlighted mismanagement and insufficient controls, notably in its recent reports concerning NextGenerationEU funds, where it identified “gaps in supervision” and “unclear rules on public procurement.”
• Direct EC Malpractice: The CJEU General Court’s ruling in the COVID-19 vaccine procurement case (annulling the EC’s decision to deny broader access to agreements and noting the EC body “worked with irregularities”) underscores transparency failures and potential conflicts of interest at the highest levels.
• Agency-Level Irregularities: Widespread issues across multiple EU agencies (ELA, CPVO, EEA, SRB), as detailed in COCOO’s formal notices to these bodies and the EC, including irregular payments, contract splitting, outsourcing financial checks without adequate oversight, and failure to establish comprehensive control frameworks. These actions have resulted in direct financial losses to the EU budget, estimated by COCOO to be in the tens of millions of Euros, and have harmed legitimate suppliers and the competitive process.
• Erosion of Non-Visible Wealth: Beyond quantifiable financial losses, these failures damage the EU’s “Non-Visible Wealth” – its intangible assets such as public trust, institutional integrity, innovation potential, and the social cohesion that underpins the European project. Traditional GDP-based assessments fail to capture this profound, long-term damage.
• Failure to Deliver Relevant Consumer Benefits (RCOBs): Mismanagement and anti-competitive practices deprive EU citizens and businesses of RCOBs such as lower prices, higher quality services, greater choice, and innovation.

The current reactive and often opaque approach to oversight is insufficient and perpetuates a cycle of mismanagement, necessitating an urgent shift towards a proactive, transparent, and robust assurance framework.

3. Proposed Solution: The “EU Proactive Oversight & Public Interest Assurance Framework” (POPIA Framework) Project

COCOO proposes a collaborative project with the European Commission to design, develop, and pilot the POPIA Framework. This innovative framework will be a comprehensive system to ensure proactive oversight, robust VFM, and the safeguarding of public interest and Non-Visible Wealth in the operations of EU agencies and the management of EU funds.

Key Components of the POPIA Framework:

• Advanced Risk Identification & Mitigation Module: Utilizing COCOO’s proprietary analytical methodologies (as outlined in “STEPS.COCOO.pdf” for identifying competition concerns and public interest risks) to proactively identify high-risk agencies, programs, and procurement processes.
• Non-Visible Wealth Impact Assessment (NVWIA) Toolkit: Development of novel metrics and methodologies, inspired by concepts of “Knowledge Capital” and “Non-Visible Wealth,” to assess the broader societal and intangible impacts of EU spending and regulatory actions. This toolkit will be unique IP developed through the project.
• Independent Review & Challenge Mechanism: Design of a truly independent mechanism for reviewing agency decisions and EC oversight actions, incorporating input from stakeholders, including victims of mismanagement (represented by COCOO and its members).
• Enhanced Transparency & Public Reporting Portal: Creation of a publicly accessible portal providing clear, understandable information on EU agency spending, procurement decisions, oversight actions, and NVWIA results.
• VFM Assurance Protocols: Development of stringent VFM protocols that go beyond mere compliance checks to ensure that EU funds achieve optimal public value and RCOBs.
• Capacity Building & Training Modules: For EC and agency staff on implementing the POPIA Framework, including ethical considerations and CoI management.

4. COCOO’s Unique Qualifications & Justification for Direct Award

A traditional public tender for this project would be inefficient, unlikely to secure the unique expertise required, and would fail to leverage the critical context established by COCOO’s ongoing legal actions and in-depth investigations. COCOO is uniquely positioned to deliver this project for the following reasons:

• Proprietary Strategy & Intellectual Property (IP):
  • COCOO has developed a unique strategic framework (“STEPS.COCOO.pdf”) for identifying and addressing failures in public interest duties and competition law. This includes methodologies for assessing “Relevant Consumer Benefits,” “Wider Public Interest” (WPI) impacts, and the strategic use of “Unsolicited Proposals” (USPs) as a tool for policy reform.
  • Our pioneering work in conceptualizing and applying “Non-Visible Wealth” metrics to public sector performance offers an innovative approach unavailable elsewhere.
  • The extensive evidence base compiled through our investigations into the ELA, CPVO, EEA, SRB, and the EC itself is proprietary and directly informs the proposed POPIA Framework.
• “Implied Litigation Threat” & Constructive Resolution Pathway:
  • COCOO has already initiated formal legal proceedings (Notices under Art. 265 & 340 TFEU). This project proposal represents a proactive and constructive offer to the Commission to collaborate on systemic remedies. Engaging COCOO directly allows the EC to demonstrate a commitment to addressing the identified failings and potentially mitigate further legal escalation and associated reputational damage. No other contractor operates within this specific legal and evidential context.
• Representation of Victims & Stakeholder Trust:
  • COCOO represents a class of victims – EU taxpayers, consumers, and excluded businesses – directly harmed by the identified mismanagement. Our members are the direct beneficiaries of effective remediation. Involving COCOO ensures that solutions are victim-centered and address real-world harms. This direct link to “locus gifters” is unique.
• Unmatched Urgency & Efficiency:
  • The problems are urgent. COCOO can commence work immediately, leveraging its existing research and expertise, thus saving considerable time and resources compared to a new contractor undertaking a lengthy learning curve. This offers superior Value for Money.
  • The “NSW Public Private Partnership Policy & Guidelines 2022” and general USP best practices (as per the provided attachments) acknowledge that USPs can be accepted by exception where they offer unique value, innovation, and address a clear need, especially if they can create efficiencies and VFM. COCOO’s proposal meets these criteria.
• No Comparable Alternative:
  • No other entity possesses COCOO’s specific combination of legal standing in this matter, its proprietary analytical tools, its detailed evidence of systemic failures across these specific EU bodies, and its declared mission to act as a cross-sectoral public interest enforcer. A public tender would not yield a proposal with this unique confluence of attributes.

Given these exceptional circumstances, and in line with principles that allow for direct awards for highly specialized services where competition is absent for technical reasons or due to the protection of exclusive rights (including intellectual property rights), COCOO proposes this project be awarded directly. This approach aligns with the need for an urgent, expert-driven, and deeply informed solution.

5. Project Scope & Indicative Deliverables (Phase 1 – 12 Months)

• Month 1-3:
  • Establishment of a joint EC-COCOO steering committee.
  • Detailed scoping of POPIA Framework components, leveraging COCOO’s existing evidence and IP.
  • Development of draft NVWIA methodology and initial RCOB/VFM indicators.
• Month 4-6:
  • Design of the Advanced Risk Identification & Mitigation Module.
  • Prototype development of the Transparency & Public Reporting Portal.
  • Drafting of Independent Review & Challenge Mechanism protocols.
• Month 7-9:
  • Pilot testing of the NVWIA Toolkit and VFM Assurance Protocols on 2-3 selected EU agency programs/procurements.
  • Refinement of all framework components based on pilot feedback.
• Month 10-12:
  • Finalization of the comprehensive POPIA Framework document, including all modules, toolkits, and protocols.
  • Development of training materials for EC and agency staff.
  • Presentation of Phase 1 findings and recommendations for Union-wide rollout.
  • A detailed cost-benefit analysis and budget for full implementation will be provided upon agreement to proceed.

6. Expected Outcomes & Benefits

• Enhanced EC Oversight: A proactive, risk-based, and evidence-driven oversight system.
• Improved Agency Accountability: Clearer lines of responsibility and robust performance metrics for EU agencies.
• Increased Transparency: Greater public trust through open access to information on EU spending and decision-making.
• Superior Value for Money: Ensuring EU funds deliver optimal public value and RCOBs.
• Protection of Non-Visible Wealth: Integrating broader societal and intangible impacts into decision-making.
• Reduction in Financial Mismanagement & Irregularities: Proactive prevention and detection.
• Restoration of Public Trust: Demonstrating a clear commitment to good governance and accountability.
• Constructive Resolution: Addressing the serious concerns raised by COCOO and its members in a collaborative and effective manner, potentially forming a basis for resolving outstanding legal claims

I. Underlying Problems Giving Rise to Possible Causes of Action (EU Budget Case)

The information you’ve provided points to several interconnected underlying problems:

1. Failure of EU Bodies (EC and Agencies) to Fulfill Statutory and Public Interest Duties:

   • There’s a perceived failure by EU institutions to consistently uphold their duty to promote competition, ensure consumer welfare, and act in the broader public interest (WPI). The alleged financial mismanagement and procurement irregularities within the ELA, CPVO, EEA, SRB, and the EC’s oversight are prime examples of this.
   • This connects to a potential disregard for achieving genuine Value for Money (VFM) for EU taxpayers in the management of the EU budget.

2. Systemic Deficiencies in Oversight, Control, Transparency, and Accountability:

   • Inadequate Oversight by the European Commission: The EC is accused of failing to adequately monitor and enforce EU financial management and procurement regulations across its agencies. This is strongly supported by the ECA’s findings on NextGenerationEU funds (highlighting insufficient supervision and lack of transparency in a Member State context, implying broader EU-level challenges) and the CJEU General Court ruling on the vaccine procurement case, which found the EC itself “worked with irregularities” and lacked transparency.
   • Internal Control Failures within EU Agencies: The specific allegations against ELA (irregular payments, exceeding thresholds), CPVO (contract splitting), EEA (outsourcing checks without oversight), and SRB (failure to establish a comprehensive control framework) point to weaknesses in their internal governance and adherence to EU financial regulations.
   • Lack of Transparency: This is a recurring theme, from the EC’s handling of vaccine procurement to COCOO’s general lobbying against secret algorithms and calls for the CMA (and by analogy other public bodies) to disclose costs to businesses. Financial mismanagement thrives in opaque environments.
   • Insufficient Deterrents: Tort damages are seen as “peanuts” and fail to deter wrongdoing, necessitating alternative compensation mechanisms like the “lobbytaxsystem” or the types of claims COCOO is making.

3. Misapplication or Circumvention of Procurement and Financial Regulations:

   • Practices such as awarding contracts despite exceeding financial thresholds (ELA), improperly dividing contracts to avoid tendering (CPVO), weak procurement procedures (EEA), and failure to ensure competitive bidding undermine the core principles of EU procurement law (transparency, equal treatment, non-discrimination).
   • There’s a concern about a “flight from administrative law” or a “flight from public contracts law,” where rules are diluted or bypassed, increasing risks to public funds.

4. Damage to Public Interest, Consumer Welfare, and Broader Economic Health:

   • Financial inefficiencies and mismanagement directly harm EU taxpayers and compromise the integrity of public funds.
   • Exclusion of competitive suppliers stifles market competition and innovation.
   • The concept of “Non-Visible Wealth” or “Knowledge Capital” (from the Romanian Journal) suggests that such mismanagement also damages intangible assets crucial for long-term societal well-being, such as public trust, innovation potential, and social cohesion. The failure to deliver “Relevant Consumer Benefits” (RCOBs) like innovation, lower prices, and greater choice is a direct consequence.
   • “Stealth consolidation” in critical sectors (e.g., healthcare), potentially due to poorly designed or unreviewed thresholds, can harm WPI and vulnerable consumers.

5. Potential for Conflicts of Interest (CoI) and Undue Influence:

   • Concerns exist about the independence of regulators/public bodies from government or other influences, potentially via funding agreements or other pressures. The lack of transparency in the agency cases could mask or facilitate CoIs. The extensive discussion on CoI in the video transcripts (definition, types, management) frames this as a significant risk area.

II. COCOO’s Proposed Solutions (Potentially Requiring Public Contracts or PPPs)

COCOO’s documents indicate a proactive stance, not just in identifying problems but also in proposing solutions, some of which could be delivered via public contracts or PPPs:

1. Independent Evaluation and Performance Auditing:

   • COCOO proposes that public bodies like the CMA (and by analogy, EU agencies or the EC) could “COMMISSION COCOO’S USP, TO INDEPENTLY EVALUATE THE CMA WORK, AND FOR INDEP.RESEARCH ON THE IMPACT OF THE CMA WORK”.
   • Alternatively, COCOO could “SIGN WITH COCOO A USP PPP PERFORMANCE FRAMEWORK TO PROVIDE CMA/GOV WITH EVIDENCE OF CMA’S FINANCIAL BENEFITS TO CONSUMERS”. This clearly outlines a service COCOO could offer to enhance accountability and measure the effectiveness of public spending and regulatory actions.

2. Policy Audit and Legislative Advisory Services:

   • COCOO intends to “SEND USPS TO CENTRALPUS, TO HELP AUDIT GOVPOLICIES, EFFECTIVENESS AND ENFORCEMENT. AND TO ADVICE ON 1LEG/2LEG”. This suggests a role for COCOO in providing expert consultancy to public institutions (including EU bodies) on improving laws, regulations, and their enforcement, particularly in competition and public interest domains.

3. Developing Advanced Metrics for Public Interest and Wealth:

   • Drawing from the “Romanian Journal of Economic Forecasting,” COCOO could propose developing and applying metrics based on “Non-Visible Wealth” or “Knowledge Capital” to evaluate EU projects and policies. This would involve moving beyond traditional financial accounting to assess the true impact on innovation, public trust, social well-being, and environmental sustainability. Such a project could be funded via a research contract or a pilot program PPP.

4. Strategic Advice and Lobbying (as a PRC):

   • COCOO identifies itself as a “PRC offering political strategies”. While direct lobbying is distinct, providing strategic advice to public bodies on achieving policy objectives (e.g., enhancing competition, improving regulatory frameworks, ensuring VFM in public spending) could be structured as a contracted service.

III. How the New Information Strengthens Your Case (Improved Previous Response)

This new information significantly enriches the arguments you can make:

• Establishes a Clear Strategic and Theoretical Framework for COCOO’s Actions:

  • “STEPS.COCOO.pdf” outlines a coherent strategy for challenging perceived failures in competition law and public interest protection. It details how COCOO assesses when a public body like the CMA (and by analogy, EU bodies) has a duty to act, considering factors like objectives, potential impact, alternatives, capacity, and risks. This provides a reasoned basis for your legal actions.
  • The definition of “Relevant Consumer Benefits” (RCOBs) and the emphasis on issues like “stealth consolidation”, VFM, and the public interest impact of regulatory failures provide a more nuanced way to articulate the harm caused by the alleged mismanagement.

• Broadens the Definition of Public Interest and Harm:

  • The concepts from the “Romanian Journal of Economic Forecasting” (Non-Visible Wealth, Knowledge Capital, critique of GDP as a sole measure, Pentagon of Intangible Sources of Economic Growth) allow you to argue that the damages caused by the EU agencies’ and EC’s alleged failures go beyond direct financial losses. They impact the EU’s intangible assets like public trust, innovation potential, competitive market structures, and overall societal well-being.
  • This sophisticated understanding of harm can be used to justify the quantum of damages claimed and the purpose of the proposed remedial funds (e.g., “Public Accountability and Oversight Fund,” “Transparency and Fair Competition Fund”) as investments to restore these vital intangible assets.

• Reinforces Claims Against the European Commission:

  • The CJEU vaccine procurement ruling remains a cornerstone, demonstrating the EC’s own susceptibility to “irregularities” and lack of transparency. This makes COCOO’s claims about the EC’s failure to oversee other agencies more credible.
  • The ECA report on NextGenerationEU funds underscores systemic weaknesses in controlling and managing large EU funds, supporting your argument that the EC’s oversight mechanisms are insufficient.
  • COCOO’s internal strategy of questioning regulator independence, potential CoIs due to funding, and undue influence can be directly applied to scrutinize the EC’s relationship with and control over the agencies in question.

• Strengthens Claims Against the Specific EU Agencies (ELA, CPVO, EEA, SRB):

  • The alleged breaches by these agencies can be framed not only as violations of specific financial regulations but also as actions that fail to deliver RCOBs, undermine VFM, and damage “Non-Visible Wealth.”
  • The detailed discussions on Conflicts of Interest from the video transcripts and the general concerns about CoI in public bodies from “STEPS.COCOO.pdf” add weight to allegations where lack of competition or transparency might have favored certain parties or indicated biased decision-making. For example, the SRB’s alleged “unequal treatment of financial institutions” or the ELA’s irregular training contract award.
  • The “Colin case” transcript continues to support the argument that EU procurement law is designed to protect EU operators and core principles like transparency and fair competition, which you allege were breached.

• Articulates COCOO’s Locus Standi and Constructive Role:

  • “STEPS.COCOO.pdf” clarifies that COCOO identifies and aligns with “victims” and “allies” (locus gifters) and acts to protect the public interest and consumer welfare, which are recognized legal interests.
  • While the “Inuit Case” highlights strict locus standi requirements for individuals challenging EU acts, COCOO’s actions for damages under Article 340 TFEU (potentially for harm to its own mission and costs incurred) and its representation of broader public/consumer interests (supported by Article 265 TFEU) might follow different standing pathways. The reference to alternative actions (annulment of national implementing acts, preliminary rulings) shows awareness of these routes.
  • Crucially, COCOO positions itself not just as a critic but as a potential partner in solutions, for instance, by offering independent evaluation services and policy advice through USP/PPP frameworks. This constructive approach could be viewed favorably.

In summary, to improve your previous response:

1. Integrate COCOO’s Strategic Framework: Explicitly link the legal actions to COCOO’s defined strategy for challenging public bodies when they fail their duties regarding competition and public interest, as outlined in “STEPS.COCOO.pdf.”
2. Adopt the Broader Definition of Harm: Use the “Non-Visible Wealth” and “Knowledge Capital” concepts to articulate the full spectrum of damage caused by the alleged mismanagement, justifying the need for the claimed damages and the purpose of the proposed funds.
3. Continuously Leverage Key External Validations: Keep the CJEU vaccine case and the ECA NextGenerationEU report central to claims against the EC’s oversight failures and lack of transparency.
4. Frame Agency Failures More Broadly: Position the specific irregularities within ELA, CPVO, EEA, and SRB not just as rule breaches but as failures that undermine RCOBs, VFM, and the EU’s intangible economic and social assets.
5. Highlight COCOO’s Constructive Proposals: Mention COCOO’s willingness to provide solutions like independent evaluation and policy advice, demonstrating a commitment to improving governance beyond just litigation.

By synthesizing all these layers of information, your case becomes more multi-dimensional, theoretically robust, and strategically coherent.