EVIDENCE GEMINI

The search strategy for the United States PACER system at [https://www.pacer.gov/], which provides access to U.S. federal court records, is to investigate the litigation history of the U.S. operations of the implicated companies. I would conduct searches in the PACER Case Locator for entities such as ACS Group, Ferrovial, and Sacyr, who have a significant presence in the United States market. The objective is to uncover any federal civil litigation, criminal cases, or bankruptcy filings related to fraud, breach of public contracts, or antitrust violations. Any finding of such cases in the U.S. would establish a pattern of high-risk corporate behavior and support your argument that the Spanish and EU authorities failed to conduct adequate due diligence before awarding them RRF funds.

For the USAspending.gov portal at [https://www.usaspending.gov/], the official database for U.S. federal spending, the strategy is to identify the track record of the implicated firms as U.S. federal contractors. I would use the advanced search to find any federal contracts, grants, or loans awarded to the U.S. subsidiaries of ACS Group and Ferrovial. The goal is to review their spending history and check for any associated performance issues or official exclusions. Discovering that a company has been flagged or debarred from U.S. federal contracting while simultaneously receiving substantial EU recovery funds would be a critical piece of evidence demonstrating the systemic failure of controls alleged in your case.

The search strategy for the WIPO Global Brand Database at [https://www.wipo.int/branddb/en/] is to map the full corporate and brand ecosystem of the target companies. I would conduct searches for all known company names, such as Dragados, Sacyr, and Carat España, to identify all associated trademarks and brand names they own globally. The purpose of this intelligence gathering is to uncover the full network of their operations, including any lesser-known subsidiaries or joint ventures. This complete picture of their corporate structure is essential for ensuring your investigation is comprehensive and that any legal action targets all relevant legal entities within their group.

For the OpenOwnership Register at [https://www.openownership.org/en/register/], the strategy is to seek public data on the beneficial ownership of the implicated companies to support your cause of action related to a lack of transparency. I would search the register for the Spanish firms like Sacyr and ACS Group to determine if they or any of their corporate structures appear in the database. The objective is to compare any findings with official records and highlight discrepancies. The absence of these major public contractors from a leading global beneficial ownership transparency initiative would strengthen your argument that Spain’s framework is opaque and fails to meet international best practices for preventing the misuse of corporate vehicles.

The strategy for the commercial Spanish business data portal Infocif at [https://www.infocif.es/] is to gather detailed financial and corporate intelligence to supplement official sources. I would use this service to obtain financial reports, director profiles, and information on corporate linkages for the sanctioned companies. The goal is to accelerate the analysis of their financial health and corporate networks. This information can be used to build a more complete dossier on each entity, identifying potential financial weaknesses or undisclosed corporate relationships that could be relevant to their eligibility for and use of public funds, in line with your CaseLink Doctrine protocols.

For the Spanish Ministry of Finance’s portal for declarations of high-ranking officials at [https://www.hacienda.gob.es/es-ES/SecretariaDeEstadoDeFuncionPublica/OficinaConflictoIntereses/Paginas/DeclaracionesdealtoscargosdelaAGE.aspx], the search strategy is to directly investigate potential conflicts of interest. I would systematically search the published declarations of assets and interests for all senior officials within the government ministries responsible for approving and overseeing the RRF funds. The objective is to find any official who has declared shareholdings, past employment, or other financial connections to the companies like Dragados or Sacyr that were awarded contracts. Uncovering such a link would constitute primary evidence of a conflict of interest at the heart of the fund allocation process, directly supporting one of your most serious causes of action.

The strategy for the website of the Spanish Congress of Deputies at [https://www.congresodiputados.es/] is to search the official record for political oversight and debate concerning the RRF. I would search the parliamentary record for all debates, written questions, and committee proceedings that mention the “Plan de Recuperación” or “fondos NextGenerationEU”. I would also search the register of interests for the Members of Parliament. The goal is to find any official records of opposition parties raising concerns about the lack of transparency or specific contract awards, which would show that these issues were known at a political level.

For the Spanish National Securities Market Commission (CNMV) at [https://www.cnmv.es/], the strategy is to obtain and analyze the official corporate filings of the implicated companies that are publicly listed in Spain. I would search for the records of ACS Group, Sacyr, and Ferrovial to access their audited annual reports and material event disclosures (“Hechos Relevantes”). The objective is to scrutinize these primary source documents for any disclosures regarding the CNMC sanctions, discussions of risks associated with public procurement, or specific details about the RRF contracts they have won. Any such disclosure would serve as a formal admission by the company that can be used as evidence.

The strategy for the Spanish National Markets and Competition Commission (CNMC) website at [https://www.cnmc.es/] is to acquire the primary evidence that forms the basis of your follow-on claim. This is the most critical source for your findings of infringement. I would use the resolutions search function to locate and download the full text of the sanctioning decisions against the companies in the construction, railway, and advertising cartels. The goal is to have the official, undeniable legal documents that prove these companies engaged in anti-competitive practices like bid-rigging. These decisions will detail the evidence and the legal reasoning for the sanctions and are the foundational documents for your argument that these firms were ineligible to receive RRF funds.

For the Transparency Portal of the Government of Catalonia at [https://transparencia.gencat.cat/], the strategy is to investigate whether the alleged mismanagement of funds extends to the regional level. I would search the portal’s databases on public contracts and subsidies, filtering for projects financed by the “Mecanisme de Recuperació i Resiliència” or “NextGenerationEU”. The objective is to determine if the same sanctioned companies are winning RRF-funded contracts at the regional level and to check for the same patterns of non-competitive awards or lack of transparency. This evidence would support your claim that the problem is systemic throughout the Spanish administration and not limited to central government bodies.

The search strategy for the AJ Bell Investment Trusts research tool at [https://www.ajbell.co.uk/markets/investment-trusts] is to further map the financial ecosystem surrounding the companies implicated in your case. Following the same logic as the shares screener, I would use this tool to identify any UK-based investment trusts that hold significant positions in the publicly-listed Spanish firms like ACS Group, Sacyr, or Ferrovial. The objective is to identify a wider group of institutional investors who have a fiduciary duty to their own shareholders to monitor governance and legal risks in their portfolio companies. Presenting these investment trusts with your findings on the mismanagement of RRF funds creates an additional channel of pressure on the companies’ boards to seek a mediated settlement to mitigate their financial and reputational risk.

For the UK Government Publications portal at [https://www.gov.uk/government/publications/], the search strategy is to find official policy documents and guidance that can serve as a benchmark for best practices in public procurement and fund management. I would search for publications from the Cabinet Office or HM Treasury containing terms like "procurement policy note", "managing public money", or "supplier code of conduct". The purpose of retrieving these documents is to establish the stringent standards the UK government applies to its own procurement and to suppliers. This can then be used in your submissions to the European Commission to create a powerful comparative argument, demonstrating that the control systems and due diligence applied by the Spanish authorities fall significantly short of these established standards.

The strategy for the UK Government Organisations directory at [https://www.gov.uk/government/organisations] is to identify the specific regulatory and oversight bodies relevant to your investigation. This directory would be used to navigate to the individual websites of entities such as the Crown Commercial Service, which leads on public procurement policy, the Infrastructure and Projects Authority, and specific sectoral regulators like the Office of Rail and Road (ORR). The goal is to perform targeted searches on these individual sites for policies, reports, or investigations concerning the UK activities of the implicated Spanish firms. This allows for a more focused and efficient evidence-gathering process than a general government-wide search.

For the London Stock Exchange Price Explorer at [https://www.londonstockexchange.com/live-markets/market-data-dashboard/price-explorer], the strategy is to gather quantitative evidence of financial harm and market sentiment. I would use this tool to track the historical share price of the publicly-listed parent companies, such as Ferrovial and ACS Group, around key dates. These dates would include the announcement of the CNMC sanctions in Spain or the publication of reports by the European Court of Auditors. The objective is to identify any significant negative share price movements following these events. This data can be used to argue that the market perceives the company’s misconduct and the resulting regulatory risks as a material threat to shareholder value, strengthening your case when engaging with institutional investors.

The search strategy for Bidstats at [https://www.bidstats.uk/], a UK public contract database, is to conduct granular analysis of the procurement history of the implicated firms’ UK operations. I would search for all past contract awards to companies like Ferrovial and Farrans Construction. The objective is to analyze the data to identify the value of contracts won, the contracting public bodies, and whether they were awarded under a competitive tender or a direct award. This information helps build a detailed intelligence dossier on these companies’ relationships with the UK public sector and can reveal patterns of bidding or winning contracts that may mirror the non-competitive practices alleged in Spain.

For the World Trade Organization’s dispute settlement page at [https://www.wto.org/english/tratop_e/dispu_e/dispu_e.htm], the strategy is to find legal precedents from international trade law that support your case, aligning with the “USP-to-WTO” play. I would search the dispute database for any cases involving the European Union as a party that relate to illegal subsidies or discriminatory public procurement rules in the construction or energy sectors. The purpose is to find the legal reasoning and panel findings in successful cases. This information can be used to strengthen the legal arguments in your Unsolicited Proposals to other governments that may have been harmed by Spain’s alleged market distortions, making your offer to manage a state-level complaint more credible.

The strategy for the U.S. Office of Government Ethics website at [https://www.oge.gov/] is to use its resources as a benchmark for best-in-class ethical standards. This site is not an evidence database for your specific case, but a repository of a robust ethics framework. I would search for its advisory opinions and regulations concerning "conflict of interest in procurement" and "post-employment conduct". The objective is to use this “gold standard” framework in your submissions to the European Commission as a point of comparison. You can argue that the Spanish system’s failure to prevent the documented abuses demonstrates a significant deficiency when measured against these internationally recognized ethics and integrity standards, thus reinforcing your Rule of Law cause of action.

For the U.S. Congress website at [https://www.congress.gov/], the strategy is to find comparative legislative and oversight precedents. I would search for U.S. legislation, such as the False Claims Act, and related Congressional Research Service reports that deal with fraud and the misuse of federal funds. I would also search for records of hearings held by oversight committees on procurement fraud. The purpose is to gather examples of how the U.S. legislative branch investigates and legislates against the types of abuses you have identified. This information can be presented to members of the European Parliament’s Budgetary Control Committee to argue for more stringent EU-level oversight mechanisms and investigative powers, using the U.S. model as an example of what is required.

The search strategy for the Espacenet patent database at [https://worldwide.espacenet.com/] and the U.S. Patent and Trademark Office search portal at [https://ppubs.uspto.gov/] is to conduct technical due diligence on the implicated companies. I would search for patents held by firms like Siemens, Alstom, and Thales, who were named as part of the railway cartel in Spain. The primary goal is to assess their intellectual property portfolios in key technology areas related to the RRF projects. While tangential, this information could become relevant if a tender was justified on the basis of a company possessing unique, patented technology. This search allows you to verify such claims and understand the technological landscape of the sectors involved.

The search strategy for the UK Register of Consultant Lobbyists at [https://www.gov.uk/government/publications/register-of-consultant-lobbyists] is to investigate potential political influence exercised by the companies implicated in your case. I would search the register for the names of the Spanish firms such as Dragados, Sacyr, and Ferrovial, as well as their parent companies like ACS Group and any known UK partners. The goal is to discover whether these companies have hired consultant lobbyists to communicate with UK Government Ministers or Permanent Secretaries on their behalf. If such lobbying activity is found, particularly in relation to public procurement policy or infrastructure projects, it would provide valuable intelligence on their efforts to influence public bodies and could be used to build a wider picture of their corporate strategy beyond the specific infringements in Spain.

For the Scottish Parliament’s Lobbying Register at [https://www.lobbying.scot/], the strategy is similar to that for the UK register but focuses on devolved matters in Scotland. I would conduct a search of the register for the same list of implicated companies and their partners, such as Sacyr and Ferrovial, who are known to be active in UK infrastructure projects. The objective is to determine if these firms are engaging in lobbying activities with Members of the Scottish Parliament or the Scottish Government. Evidence of such activity would contribute to the intelligence dossier on these companies, mapping their political engagement across the UK and helping to identify any patterns of attempting to influence public procurement at multiple levels of government.

The strategy for the UK Case Tracker for Civil Appeals at [https://casetracker.justice.gov.uk/] is to monitor high-level UK litigation involving the relevant companies. I would conduct searches using the names of the UK-based entities or parent companies, such as Ferrovial or ACS Group, as a party to any appeal in the Court of Appeal Civil Division. The purpose is to identify any judgments or ongoing appeals related to competition law, contract disputes, or public procurement. A judgment from the Court of Appeal would provide significant legal precedent, and monitoring the tracker would serve as an early warning system for legal developments that could influence your own case strategy and legal arguments.

Regarding the Royal Courts of Justice Cause List at [https://www.gov.uk/government/publications/royal-courts-of-justice-cause-list], the strategy is one of real-time intelligence gathering rather than historical research. As this publication lists upcoming hearings, I would establish a process to monitor it daily for mentions of the UK-linked companies implicated in your case. The goal is to identify new litigation involving these firms as it enters the UK High Court. This proactive monitoring would provide immediate awareness of new legal challenges that could produce relevant evidence or impact the companies’ financial or reputational standing, offering tactical advantages for your own campaign.

For the Find a Tender service at [https://www.find-tender.service.gov.uk/], the UK’s high-value public procurement portal, the strategy is twofold, aligning with your CaseLink Doctrine. Firstly, I would search for past contract award notices to identify any UK public contracts won by the implicated firms, which helps to build a profile of their public sector business and relationships. Secondly, I would search for future opportunities and pipeline notices for services your own organization could provide, such as auditing, legal, or compliance consultancy. This allows you to identify public bodies with stated needs that you can target with an Unsolicited Proposal (USP), turning this intelligence tool into a potential source of revenue and influence.

The strategy for LobbyFacts.eu at [https://www.lobbyfacts.eu/], which provides data from the EU Transparency Register, is to investigate the lobbying activities of the sanctioned Spanish companies at the heart of the European Union. I would search for the corporate profiles of ACS Group, Sacyr, and Ferrovial to quantify their lobbying expenditure, identify the specific lobbyists they employ, and see which European Commission and Parliament officials they have been meeting with. The objective is to find evidence of significant lobbying efforts directed at the very institutions responsible for overseeing the RRF funds. This information can be used to construct a powerful narrative of undue corporate influence, supporting the cause of action that there is a systemic risk to the EU budget due to potential regulatory capture.

For the European Commission’s Press Corner at [https://ec.europa.eu/commission/presscorner/home/en], the strategy is to find official statements that could be used as evidence of the Commission’s public position or its awareness of the situation. I would search the archive for all press releases and speeches mentioning "Spain" AND ("Recovery and Resilience Facility" OR "RRF"). The goal is to find any statements where the Commission has publicly praised Spain’s implementation of the RRF. Such statements, when contrasted with the evidence of mismanagement and the Commission’s private refusal to act, can be used to highlight a significant inconsistency and support a claim of maladministration or failure to act under Article 265 TFEU.

Regarding the EU Online Dispute Resolution (ODR) platform at [https://ec.europa.eu/consumers/odr/], I must state honestly that this tool is not relevant to your case. The ODR platform is designed exclusively for resolving disputes between consumers and traders concerning online purchases of goods or services. Your case involves the mismanagement of public funds, competition law, and rule of law issues at a state and corporate level. Therefore, a search on this platform would not yield any information or evidence pertinent to your identified causes of action.

The Your Europe business portal’s page on Tenders at [https://europa.eu/youreurope/business/finance-funding/getting-funding/tenders/index_en.htm] serves as a gateway to the official Tenders Electronic Daily (TED) database. The strategy is to follow the link to TED and there, conduct a detailed search for the contract award notices related to the Spanish RRF. I would search for notices from Spanish contracting authorities that name the sanctioned companies like Dragados and Sacyr as the beneficiaries. The goal is to retrieve the primary documentary evidence of the specific contracts that were awarded, including their value and scope. This official documentation is irrefutable proof of the core allegation that companies with prior infringements received RRF-funded contracts.

The strategy for the AJ Bell shares screener at [https://www.ajbell.co.uk/market-research/screener/shares] is to conduct financial intelligence on the ownership structure of the publicly listed companies involved in the case. I would use the screener to identify the major institutional shareholders, such as pension funds, investment managers, and sovereign wealth funds, that have significant equity holdings in companies like ACS Group, Ferrovial, and Sacyr. The objective is to identify powerful financial stakeholders who have a fiduciary duty to protect their investments from legal and reputational risk. These institutional investors can be approached with your findings, creating a new pressure point on the companies’ management and board of directors to address the allegations and seek a resolution.