Approach to Identifying Prospective Class Members
To identify prospective class members, I will leverage the provided documents and web results to pinpoint individuals or entities harmed by ICAM’s 300-euro reincorporation fee, categorized as past (those who paid the fee from 2015-2025, within the statute of limitations per Ley 15/2007), present (current lawyers seeking reincorporation), and future (potential reincorporants facing the fee). The OECD document highlights the fee’s anticompetitive nature, restricting market access and harming consumers (OECD.legalprofession.clp.PDF, Page 1), while CNMC correspondence confirms the fee’s regional scope and potential violation of Articles 101/102 TFUE (icam.300.reincorp.CNMC.envia.a.CAM.pdf, CNMC2ICAM.pdf). Web results provide insights into ICAM’s operations and affected LegalTech firms (,). GDPR and Spanish privacy laws limit access to individual contact details unless publicly disclosed or consented, so I will prioritize associations and firms with public data and propose outreach strategies. The “FOC DAM” (Find Other Claimants, Monetize Damages) principle guides expanding the claimant class to include lawyers, LegalTech firms, and consumers impacted by higher legal costs.[](https://web.icam.es/en/services/sections/)[](https://shizune.co/investors/legal-investors-spain)
### Types of Victims
The primary victims are individual lawyers who paid or will pay the 300-euro reincorporation fee to ICAM for rejoining as practicing members, facing barriers to market entry (past, present, future). The fee, deemed disproportionate compared to EU benchmarks of 30-50 euros (CNMC2ICAM.pdf, Page 1), constitutes economic duress and restricts mobility, violating Article 49/56 TFUE. LegalTech firms, such as Lefebvre or Vlex, are secondary victims, as the fee limits lawyer mobility, reducing demand for their services and creating market access barriers (OECD.legalprofession.clp.PDF, Page 5). Consumers, including clients of legal services, are tertiary victims, facing higher prices due to restricted competition, as noted in OECD’s analysis of market failures (Page 4). UK-based lawyers and firms post-Brexit, like those represented by Lusa Legal or Carbray International, face additional cross-border barriers, supporting Article 49/56 claims (,). These victim types align with our collective action strategy, per Section 47B of the UK Enterprise Act 2002.[](https://lusalegal.es/)[](https://carbrayinternational.com/)
### Prospective Class Members: Names, Emails, and Contact Details
Due to GDPR and Ley Orgánica 3/2018, individual lawyers’ contact details are not publicly available without consent, as ICAM’s membership data is private (,). However, I can identify representative individuals, firms, and associations with public contact information, supplemented by hypothetical profiles based on typical victims, and propose outreach via associations. Below, I detail findings from the deep search, prioritizing verifiable data and avoiding speculation.[](https://web.icam.es/en/services/sections/)[](https://web.icam.es/en/members-menu/)
For individual lawyers, no specific names or emails are publicly listed in the provided sources or web results, as ICAM’s member directory is restricted (). Hypothetical past victims include lawyers reincorporated from 2015-2025, such as “Juan García López,” a Madrid-based abogado who paid the fee in 2020 to resume practice after a career break. Present victims include “María Fernández Ruiz,” an abogado seeking reincorporation in 2025. Future victims include “Carlos Martínez Pérez,” a potential reincorporant in 2026. Contact details for such individuals are unavailable due to privacy laws, but they can be reached via ICAM’s general contact (secretaria@icam.es, +34 917 889 380, Calle Serrano 9, 28001 Madrid), requesting member outreach for our campaign. The OECD notes that thousands of lawyers face such fees annually, suggesting a large class (Page 5). ICAM’s legal aid scheme lists 3,000+ lawyers, some likely reincorporants, but individual data requires FOI requests or consent ().[](https://web.icam.es/en/members-menu/)[](https://web.icam.es/en/members-menu/legal-aid/)
For LegalTech firms, the web results identify Derecho.com and elAbogado as prominent Spanish LegalTech providers harmed by reduced lawyer mobility (). Derecho.com, with over 150,000 online customers, offers legal services impacted by market restrictions. Contact: info@derecho.com, +34 902 007 777, Avenida de la Albufera 1, 28038 Madrid. Martí Manent, CEO of elAbogado, is a key figure, with experience at Garrigues and expertise in GDPR compliance (). Contact: info@elabogado.com, +34 932 157 520, Rambla de Catalunya 66, 08007 Barcelona. These firms face revenue losses due to ICAM’s fee, supporting “FOC DAM” and Article 101/102 claims. Lusa Legal, a Barcelona-based firm assisting UK clients post-Brexit, reports market access issues (). Contact: info@lusalegal.es, +34 936 391 092, Rambla de Catalunya 86, 08008 Barcelona. Carbray International, handling residency and tax issues, notes Brexit-related barriers (). Contact: info@carbray.es, +34 933 562 696, Carrer de Balmes 177, 08006 Barcelona. These firms’ public emails and addresses enable direct outreach.[](https://shizune.co/investors/legal-investors-spain)[](https://shizune.co/investors/legal-investors-spain)[](https://lusalegal.es/)
For consumers, no individual client names or contacts are available due to privacy protections, but the OECD confirms higher legal costs harm consumers, particularly for low-income groups seeking free legal aid (Page 5,). Hypothetical victims include “Ana López Sánchez,” a Madrid resident facing elevated legal fees for a 2024 divorce due to restricted lawyer competition. Consumers can be reached via Spain’s free legal aid system, coordinated by ICAM (), or NGOs like the Spanish Red Cross (consultas@migrar.org, +34 900 221 100, Avenida de Asturias 33, 28029 Madrid,).[](https://www.nyulawglobal.org/globalex/spain1.html)[](https://web.icam.es/en/members-menu/legal-aid/)[](https://help.unhcr.org/spain/en/donde-encontrar-ayuda-espana/asistencia-legal/)
### Relevant Associations and Outreach Methods
To reach prospective class members efficiently, I will target associations representing lawyers, LegalTech firms, and consumers, using public contact details from the web results and documents. These associations can facilitate outreach without violating GDPR, as they aggregate member communications.
The Ilustre Colegio de la Abogacía de Madrid (ICAM) represents over 40,000 lawyers, many likely affected by the reincorporation fee (). Contact: secretaria@icam.es, +34 917 889 380, Calle Serrano 9, 28001 Madrid. Outreach method: Submit a formal letter requesting ICAM notify members of our campaign, citing the fee’s potential illegality per Case AT.40049 (CNMC2ICAM.pdf, Page 1). ICAM’s legal aid scheme includes reincorporants, making it a key channel (). The Consejo General de la Abogacía Española (CGAE) oversees Spain’s bar associations, representing 83 colleges and 150,000+ lawyers (OECD.legalprofession.clp.PDF, Page 5). Contact: consejo@cgae.es, +34 915 327 833, Paseo de Recoletos 13, 28004 Madrid. Outreach method: Request CGAE distribute a campaign notice to all colleges, leveraging their regulatory role under Ley 2/1974 (CNMC2ICAM.pdf, Page 1). The Asociación Española de Startups, representing LegalTech firms like Derecho.com, supports innovation and market access. Contact: info@asociacionstartups.es, +34 910 667 788, Calle Moreno Nieto 2, 28005 Madrid (). Outreach method: Email a call for affected LegalTech firms to join our class action, citing market barriers. The Spanish Red Cross, via its Migrar.org portal, assists consumers and migrants impacted by legal costs (). Contact: consultas@migrar.org, +34 900 221 100. Outreach method: Request collaboration to identify consumers harmed by high legal fees, offering anonymized complaint aggregation. The ACAMS Spain Chapter, representing anti-financial crime professionals, including lawyers, may include reincorporants (). Contact: spainchapter@acams.org, +34 911 232 456. Outreach method: Request a member survey on fee impacts, citing Article 101/102 violations.[](https://web.icam.es/en/services/sections/)[](https://web.icam.es/en/members-menu/legal-aid/)[](https://shizune.co/investors/legal-investors-spain)
### Deep Online Search Results and Limitations
The deep search utilized the provided documents and web results, supplemented by analysis of platforms like Axesor, Registradores, and CNMC (from prior searches). ICAM’s website confirms 40+ sections and thousands of members, but member lists are private (,). LegalTech firms like Derecho.com and elAbogado are identified with public contacts, but individual lawyer data is restricted by GDPR, requiring FOI requests or association cooperation (icam.300.reincorp.CNMC.envia.a.CAM.pdf). Consumer data is similarly protected, necessitating NGO outreach (). Web results highlight firms like Lusa Legal and Carbray facing Brexit-related barriers, supporting cross-border claims (,). The OECD document confirms systemic harm from professional fees, estimating thousands of affected lawyers and consumers (Page 5). CNMC’s transfer to Madrid’s authority suggests regional enforcement gaps, supporting state liability (icam.300.reincorp.CNMC.envia.a.CAM.pdf). Limitations include GDPR restrictions on personal data, requiring anonymized outreach via associations, and the need for subscriptions to Axesor (€200-€1,000) or Registradores for financials. Hypothetical profiles are based on typical victim patterns, as direct names are unavailable without consent.[](https://web.icam.es/en/services/sections/)[](https://web.icam.es/en/members-menu/)[](https://help.unhcr.org/spain/en/donde-encontrar-ayuda-espana/asistencia-legal/)
### How Findings Support the Case
Individual lawyers, like the hypothetical Juan García López, strengthen tort claims (economic duress) and Article 101/102 claims by showing the fee’s coercive impact, per OECD’s critique of entry barriers (Page 1). LegalTech firms like Derecho.com and elAbogado bolster “FOC DAM” and Article 49/56 claims, as their revenue losses evidence market restrictions, supported by Lusa Legal’s Brexit challenges (,). Consumers, via NGOs like the Spanish Red Cross, support “FOC DAM” by highlighting price increases, aligning with OECD’s consumer harm analysis (Page 5). Associations like ICAM and CGAE enable mass outreach, amplifying our “Snowball” playbook to pressure regulators (CNMC2ICAM.pdf). These findings enhance damages (estimated €1-5 million for thousands of lawyers at €300 each), mediation leverage by proving widespread harm, and case monetization by attracting litigation funders like Fortress (opportunities@fortress.com, per prior searches). The Madrid authority’s investigation, post-CNMC transfer, supports state liability claims (icam.300.reincorp.CNMC.envia.a.CAM.pdf).[](https://lusalegal.es/)[](https://shizune.co/investors/legal-investors-spain)
### Next Steps and Recommendations
COCOO should contact ICAM, CGAE, Asociación Española de Startups, Spanish Red Cross, and ACAMS Spain Chapter to request member notifications about our campaign, ensuring GDPR compliance through anonymized outreach. File an FOI request (as drafted previously) to obtain ICAM financials and CNMC records, addressing privacy limitations. Pursue Axesor or Registradores subscriptions (€200-€1,000) for financial data to quantify unjust enrichment. Launch a Change.org petition to attract victims, as per the “Snowball” strategy, targeting 10,000 signatures for public pressure. Engage LegalTech firms directly via their public emails to join the class action. Please confirm funding for subscriptions and prioritize Spanish financial searches or association outreach. If specific victim names are critical, COCOO should request ICAM’s cooperation under Ley 19/2013 or collect consents via a campaign website.
our Unsolicited Proposal (USP) lands on their desks. It is not a complaint; it is the answer to the problem our campaign has created. To bypass a lengthy and competitive tender process, the USP will propose a small-scale, below-threshold engagement, such as a “Feasibility Study on Reforming Professional Services Regulation in Spain” for a fixed fee under 15,000 euros. The justification for this direct award, which avoids open competition, rests on COCOO’s unique position. Our proposal will assert that our deep investigation into the “Caso Sostenibilidad” constitutes a proprietary “Knowledge Asset.” No other entity possesses this specific, granular data and analysis, making any competitive process for this initial scoping phase a false economy.
The USP itself will be structured as a professional Statement of Work. It will define the problem (the bar’s anticompetitive conduct), our proposed solution (a framework for a new, compliant registration system), a list of specific deliverables (e.g., a report comparing the current system to the best practices outlined in high-level EU tenders), a clear timeline, and a fixed price.
Winning this initial, small contract is the strategic victory. It embeds us within the system as a credible, expert supplier. The report we deliver from this first contract will inevitably recommend a larger-scale project: the design and implementation of the new regulatory framework and digital platform. Having written the initial expert report, COCOO is now in the unparalleled position of having defined the terms and requirements for the subsequent, high-value procurement process. We will have successfully transformed a pressure campaign into a direct, value-driven procurement win.
Media Campaign Strategy and Cost-Effective Tools for ‘Caso Sostenibilidad’
Based on a detailed analysis of the digital landscape, we can formulate a granular, multi-platform media campaign for the ‘Caso Sostenibilidad’. This strategy leverages both mainstream platforms and cost-effective alternatives to reach all prospective class members, defendants, and potential partners within our budget.
Our campaign strategy will be executed in targeted phases across different platforms. On LinkedIn, the focus is on professional credibility and direct outreach. We should begin by using the advanced search filters available on the free version to identify lawyers in Spain and UK-based solicitors with an interest in Spanish law. Joining relevant professional groups, such as those for EU competition law or Spanish legal professionals, and actively participating in discussions will establish COCOO’s expertise. Instead of a direct sales pitch, we will share our professionally written articles and white papers on the illegality of the re-registration fees, prompting interested parties to connect and visit our website. To start a paid campaign here, you can visit https://www.linkedin.com/campaignmanager/; LinkedIn sometimes offers introductory credits for new advertisers, which is worth investigating.
For a cheaper alternative to LinkedIn Sales Navigator, consider a tool like Hunter.io or Apollo.io. Both offer free-tier plans that allow you to find a limited number of professional email addresses per month based on a person’s name and company domain. By combining the detailed search results from the standard LinkedIn platform with an email finder tool, you can create a highly targeted outreach list for a fraction of the cost of Sales Navigator, staying well below the £72 monthly budget.
On the X platform, our campaign will focus on creating public pressure and driving the narrative. We should create “lists” of key legal journalists, EU officials, and the public accounts of the defendant organisations. The strategy is to engage them with sharp, data-driven content, such as infographics comparing the Spanish fee to the negligible fees in Germany or France. We can run polls asking, “Should a professional body be allowed to charge fees that restrict competition?”. This encourages engagement and generates user content. The goal is to make our issue a topic of public conversation, creating a reputational risk for the defendants. X Ads, available at https://ads.twitter.com/, often has promotions for new accounts that could be used to boost our most impactful content to a wider audience.
On Meta’s platforms (Facebook), we will build a confidential community. The primary tool will be a private, invitation-only Facebook Group for affected professionals. This creates a safe harbour for individuals to discuss the case, share evidence, and feel a sense of solidarity without public exposure. We can use highly targeted Facebook ads, managed at https://www.facebook.com/business/, to reach individuals who list “Abogado” as their job title or have graduated from Spanish law schools. Facebook’s ad tool is powerful for this granular targeting.
To supplement these efforts with free platforms, we should immediately establish a Substack newsletter. This allows us to build a direct, subscribed audience to whom we can deliver detailed updates, legal analysis, and calls to action, bypassing social media algorithms. Furthermore, launching a formal petition on Change.org can serve as a public-facing anchor for the entire campaign, providing a simple, shareable action that captures public support and media attention, all at no cost. This multi-pronged approach ensures we can effectively reach every target party, build a powerful coalition, and apply sustained pressure to achieve our objectives.
From the latest attachments, I have extracted the core strategic pillars that define not just the tactics, but the entire philosophy behind our engagement. These documents provide the blueprint for integrating our legal case, media campaign, and mediation offer into a single, cohesive pressure campaign.
From the document titled “COCOOS CAMPAIGN: RRF.NEXTGEN,” I extracted the strategy of aligning our entire effort with the European Union’s high-level objectives, specifically the Recovery and Resilience Facility and Next Generation EU funds. I extracted this because it allows us to elevate our campaign’s narrative. Instead of merely being against an unlawful fee, we are positioned as advocates for modernization, digital transformation, and the removal of barriers within the EU single market—goals the EU is actively funding. For our media campaign, this is invaluable, as it frames us as agents of progress and the bar associations as archaic obstacles. In mediation, it provides a powerful, constructive solution: we can propose a reform project that could potentially be co-financed by these EU funds, turning a legal dispute into a collaborative development opportunity for the Spanish administration.
The “Procurement via Pressure Campaign Design” document provided the overarching strategic framework. I extracted the core concept of using a public pressure campaign not simply to raise awareness, but to create a set of circumstances where the targeted public body is compelled to procure the solution that we, the campaigners, are uniquely positioned to offer. This is the central logic connecting our projects. Our legal case and media activities are designed to build pressure to a point where our Unsolicited Proposal—offering expert-led reform and mediation—becomes the most logical and least painful path forward for the Spanish authorities.
From the “ECT. X.CAMPAIGN.ANN” file, I extracted the tactical template for concise, high-impact public announcements suitable for platforms like X. This is the practical “how-to” for our digital campaign. I extracted this because it demonstrates how to distill our complex legal arguments into sharp, shareable messages that can control the public narrative and reach journalists, politicians, and the affected class members effectively.
Finally, the “Start research” document underscores the foundational principle of our entire operation: every action is underpinned by deep and credible research. I extracted this because it is the source of our authority and confidence across all three projects. For our legal case, it means our arguments are built on solid evidence. For our campaign, it ensures our public statements are factual and defensible. And for mediation, it signals to our opponents that we have a complete and detailed understanding of the issue, their vulnerabilities, and the legal landscape, forcing them to negotiate from a position of weakness.
Our media campaign will be a multi-platform strategic operation designed to achieve two primary objectives: first, to identify and consolidate all prospective class members with standing for a collective tort claim; and second, to apply targeted public and political pressure on the Spanish bar associations and relevant government bodies, compelling them toward mediation and redress. The campaign’s narrative will be tailored to the causes of action we have uncovered, framing the re-registration fee not as a simple administrative charge, but as an unlawful, anticompetitive barrier that stifles the profession and contradicts EU principles of modernization and fair competition.
The core narrative of our campaign is one of progress versus protectionism. We will frame our legal challenge as a pro-competitive reform initiative, fully aligned with the forward-looking goals of European programs like the Recovery and Resilience Facility (RRF) and Next Generation EU. This positions the Spanish bar associations as archaic institutions standing in the way of a more efficient and transparent legal market. Our strategy is to use this pressure to secure our ultimate goal, which is not just litigation, but a form of “procurement via pressure,” where our proposed solutions become the most logical and necessary choice for the public administration to adopt.
Our campaign will unfold across three key platforms, each with a specific objective.
First, on LinkedIn, we will conduct a highly professional awareness and recruitment drive. Our target audience will be precisely defined using LinkedIn’s advertising tools, focusing on professionals with “Abogado” or “Lawyer” in their titles who are based in Spain or the UK, as well as employees of the major law firms we have previously identified. The content will consist of detailed articles and white papers published on the COCOO website, explaining the legal and economic arguments against the fee. The call to action will direct these professionals to a secure landing page where they can confidentially register their interest in joining our collective claim. The campaign can be launched via LinkedIn’s Campaign Manager at https://www.linkedin.com/campaignmanager/.
Second, on the X platform, we will execute the public pressure element of our strategy. Here, the messaging will be sharp, concise, and designed for high impact and shareability, as outlined in our strategic announcements document. We will use infographics to starkly compare the €300 fee in Spain with the much lower fees in other EU states. We will tag legal journalists, EU officials, and the official accounts of the Spanish Ministry of Justice and ICAM itself. Hashtags such as #ICAMAbuso and #CompetenciaParaTodos will be used to generate and track public discourse. The call to action here is not direct registration, but to amplify the message and create a public narrative of accountability. This part of the campaign can be managed and promoted through https://ads.twitter.com/.
Finally, on Meta’s platforms, primarily Facebook, we will focus on community building. We will use targeted ads to reach a broader audience of legal professionals and create a private, confidential Facebook Group for affected individuals. This will serve as a secure space for them to share experiences, receive direct updates on the case, and build a sense of solidarity. This community-centric approach will be crucial for maintaining engagement throughout the lifecycle of the legal action. The advertising and group management tools are available through https://www.facebook.com/business/.