VICTIMS
Types of Prospective Class Members (Victims) and Their Relevance to the Case
The UK national debt case, as outlined in “nationaldebt.cocoo.uk” and prior submissions, involves claims against Gilt-Edged Market Makers (GEMMs—Citigroup, HSBC, Morgan Stanley, Royal Bank of Canada) for anti-competitive behavior (per CMA’s 2019 infringement decision, Case 50607) and tort claims against HM Treasury/DMO for negligence, misfeasance, breach of statutory duty, and anti-competitive vertical agreements. Potential class members are individuals or entities harmed by inflated gilt prices, mismanaged debt issuance, or lack of beneficial ownership (BO) transparency, which increased public debt costs and economic burdens. Below are the types of victims, their characteristics, and their relevance:
**1. UK Taxpayers (Individuals)**
– **Description**: Ordinary UK residents who bear the financial burden of increased national debt servicing costs due to alleged DMO mismanagement (e.g., over-reliance on index-linked gilts, 2009–2013, per “UK DEBT_250414_154434.txt”) and GEMM collusion inflating gilt prices, as per CMA findings . Taxpayers are indirectly harmed through higher taxes or reduced public services, as debt servicing costs (e.g., £83 billion in 2024 per NAO) strain public finances.
– **Impact**: Negligence in gilt issuance and anti-competitive pricing by GEMMs increased borrowing costs, passing the burden to taxpayers. Lack of BO transparency (per “TI_ BORs.pdf”) may have hidden foreign profiteering, further harming public interest.
– **Estimated Scale**: Millions of UK taxpayers (approx. 32 million income taxpayers in 2025, per HMRC estimates).
**2. Pension Funds and Retirees**
– **Description**: UK pension funds (e.g., public sector, private schemes) and retirees holding or relying on gilts, affected by manipulated gilt prices or mismanaged issuance reducing returns, per “nationaldebt.cocoo.uk.” Index-linked gilts’ inflation exposure (35% of DMO portfolio, 2009–2013) eroded real returns during high inflation.
– **Impact**: Anti-competitive GEMM practices (e.g., price-fixing in 2019 CMA case) reduced gilt yields, harming pension fund solvency and retiree income. DMO’s failure to mitigate risks (per NAO 2012, SEARCHLINK 3) exacerbated losses.
– **Estimated Scale**: Hundreds of pension funds (e.g., USS, Local Government Pension Scheme) and millions of retirees (approx. 12 million pensioners in 2025, per ONS).
**3. Small Businesses and Entrepreneurs**
– **Description**: UK small businesses impacted by higher borrowing costs or economic instability from mismanaged national debt, as higher gilt yields raise commercial loan rates, per IFS findings (SEARCHLINK 4). Anti-competitive GEMM behavior may have inflated financing costs.
– **Impact**: DMO’s mismanagement (e.g., failure to comply with “full funding rule,” per “UK DEBT_250414_154434.txt”) and GEMM collusion increased market uncertainty, raising interest rates and limiting small business access to credit.
– **Estimated Scale**: Approx. 5.6 million UK SMEs in 2025, per FSB data.
**4. Public Sector Entities (Local Authorities, NHS Trusts)**
– **Description**: Local councils and NHS trusts borrowing from the Public Works Loan Board (PWLB, managed by DMO) faced higher interest rates due to gilt market distortions, per . Mismanagement and opacity in gilt issuance increased PWLB loan costs.
– **Impact**: Anti-competitive practices and DMO negligence raised borrowing costs, reducing funds for public services (e.g., healthcare, infrastructure), indirectly harming citizens reliant on these services.
– **Estimated Scale**: Over 300 local authorities and 200 NHS trusts in England and Wales.
**5. Insolvent Debtors (Individuals and Businesses)**
– **Description**: Individuals or businesses declared bankrupt or under Debt Relief Orders (DROs) due to economic pressures exacerbated by high national debt costs, per . These victims faced financial distress partly due to economic conditions linked to DMO mismanagement.
– **Impact**: Higher debt servicing costs reduced public spending, worsening economic conditions and pushing vulnerable debtors into insolvency. Lack of BO transparency may have enabled predatory creditor practices.
– **Estimated Scale**: Approx. 80,000 personal insolvencies and 20,000 business insolvencies annually (2025 estimate, per Insolvency Service).
**6. Future Taxpayers (Generational Victims)**
– **Description**: Future UK taxpayers (e.g., younger generations, Gen Z, Millennials) who will inherit higher debt servicing costs due to past DMO mismanagement and GEMM collusion, per “nationaldebt.cocoo.uk.” Long-term gilt issuance (2009–2013) locked in high costs.
– **Impact**: Ongoing economic burden from inflated debt costs will increase future taxes or reduce services, harming quality of life.
– **Estimated Scale**: Millions of future taxpayers (unquantifiable but includes those under 40 today, per ONS).
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### How to Reach Prospective Class Members and Relevant Associations
Directly contacting individuals by name or email is not feasible due to privacy laws and lack of public data. Instead, I propose reaching potential class members through trusted UK associations and organizations that represent or support these victim groups. These entities can facilitate outreach, verify claims, and aggregate class members for your case, enhancing its sale potential (e.g., to buyers like Fortress, per “HOW 2 SELL MY LITIGATION.txt”). Below, I list relevant associations, their contact details, how best to reach them, and their role in connecting with victims, ensuring compliance with GDPR and FOIA limitations.
**1. Citizens Advice (Represents Taxpayers, Insolvent Debtors)**
– **Role**: Provides free debt advice and consumer protection support, ideal for reaching taxpayers and debtors harmed by economic pressures from national debt mismanagement. They handle complaints about creditor harassment, relevant to insolvency victims .
– **Contact Details**:
– Phone: 0800 240 4420 (debt helpline, free, 9am–8pm Mon–Fri, 9:30am–1pm Sat)
– Email: Use online contact form at www.citizensadvice.org.uk (no direct email provided to protect client privacy)
– Address: Citizens Advice, 3rd Floor North, 200 Aldersgate, London EC1A 4HD
– **How to Reach**: Use the online contact form to pitch your case, explaining the competition and tort claims and how taxpayers/debtors are victims. Request collaboration to identify affected clients anonymously via their debt helpline or local branches. Follow up by phone for urgent inquiries, citing your case’s public interest (transparency in debt management).
– **Why Effective**: Citizens Advice serves millions annually (over 2 million debt inquiries in 2024, per their reports), offering a broad reach to taxpayers and debtors. Their FCA regulation ensures credibility for class action outreach.
**2. National Debtline (Represents Taxpayers, Insolvent Debtors)**
– **Role**: Free, independent debt advice charity supporting individuals struggling with debt, including those impacted by economic fallout from national debt costs . Can connect with insolvent debtors and taxpayers.
– **Contact Details**:
– Phone: 0808 808 4000 (free, 9am–8pm Mon–Fri, 9:30am–1pm Sat)
– Email: Use webform at www.nationaldebtline.org/contact-us
– Address: National Debtline, Tricorn House, 51–53 Hagley Road, Birmingham B16 8TP
– **How to Reach**: Submit a detailed inquiry via the webform, outlining the case (GEMM collusion, DMO negligence) and requesting anonymized outreach to clients affected by debt-related economic pressures. Emphasize public interest to align with their mission. Follow up by phone to discuss partnership.
– **Why Effective**: National Debtline helped over 150,000 clients in 2024 (per their site), with expertise in insolvency and economic hardship, making it a key channel for debtor victims.
**3. Federation of Small Businesses (FSB) (Represents Small Businesses)**
– **Role**: Advocates for UK SMEs, many impacted by high borrowing costs linked to gilt market distortions . Can facilitate outreach to businesses harmed by economic instability.
– **Contact Details**:
– Phone: 0808 202 0888 (membership inquiries, 9am–5pm Mon–Fri)
– Email: membership@fsb.org.uk
– Address: FSB, Blackpool Enterprise Centre, 291–305 Lytham Road, Blackpool FY4 1EW
– **How to Reach**: Email membership@fsb.org.uk with a proposal to identify SMEs affected by high interest rates or economic instability tied to DMO mismanagement. Request a meeting with their policy team to discuss class action inclusion. Cite “nationaldebt.cocoo.uk” data to show relevance.
– **Why Effective**: FSB represents over 150,000 SMEs, with influence in policy and legal advocacy, ideal for aggregating business victims.
**4. The Pensions Regulator (TPR) (Represents Pension Funds, Retirees)**
– **Role**: Regulates UK pension schemes, including those holding gilts affected by GEMM collusion or DMO mismanagement . Can connect with pension funds and indirectly reach retirees.
– **Contact Details**:
– Phone: 0345 600 7066 (general inquiries, 9am–5pm Mon–Fri)
– Email: customersupport@tpr.gov.uk
– Address: The Pensions Regulator, Napier House, Trafalgar Place, Brighton BN1 4DW
– **How to Reach**: Email customersupport@tpr.gov.uk, detailing how pension funds were harmed by gilt price manipulation (per CMA 2019) and requesting anonymized outreach to affected schemes. Highlight public interest in transparency (per “TI_ BORs.pdf”). Follow up by phone to discuss regulatory support.
– **Why Effective**: TPR oversees 5,800 pension schemes (approx. £2 trillion in assets), offering a direct channel to funds impacted by gilt market issues.
**5. Local Government Association (LGA) (Represents Local Authorities)**
– **Role**: Represents UK local councils borrowing from PWLB, affected by higher rates due to DMO mismanagement . Can facilitate outreach to public sector victims.
– **Contact Details**:
– Phone: 020 7664 3000 (9am–5pm Mon–Fri)
– Email: info@local.gov.uk
– Address: Local Government Association, 18 Smith Square, Westminster, London SW1P 3HZ
– **How to Reach**: Email info@local.gov.uk with a case summary, explaining how PWLB loan costs rose due to gilt market issues. Request collaboration to identify affected councils for the class action. Cite NAO findings (SEARCHLINK 3).
– **Why Effective**: LGA represents over 300 councils, many reliant on PWLB, making it a key conduit for public sector victims.
**6. NHS Confederation (Represents NHS Trusts)**
– **Role**: Advocates for NHS trusts, some of which borrow from PWLB and face budget constraints from national debt costs . Can connect with trusts harmed by economic pressures.
– **Contact Details**:
– Phone: 020 7799 6666 (9am–5pm Mon–Fri)
– Email: enquiries@nhsconfed.org
– Address: NHS Confederation, 2nd Floor, 18 Smith Square, London SW1P 3HZ
– **How to Reach**: Email enquiries@nhsconfed.org, outlining the case’s impact on NHS budgets via PWLB rates. Request anonymized outreach to trusts for class action inclusion. Reference “UK DEBT_250414_154434.txt” on debt costs.
– **Why Effective**: Represents over 500 NHS organizations, offering access to trusts affected by fiscal mismanagement.
**7. Insolvency Service (Represents Insolvent Debtors)**
– **Role**: Manages bankruptcy and DROs, ideal for identifying debtors impacted by economic conditions tied to national debt . Can provide anonymized data on insolvency trends.
– **Contact Details**:
– Phone: 0300 678 0015 (general inquiries, 9am–5pm Mon–Fri)
– Email: legalservices@insolvency.gov.uk
– Address: Insolvency Service, PO Box 16668, Birmingham B2 2HE
– **How to Reach**: Email legalservices@insolvency.gov.uk, requesting anonymized data on insolvency cases (2009–2025) linked to economic pressures from debt mismanagement. Cite public interest and “SEARCHLINK Model.pdf” (Snowball strategy).
– **Why Effective**: Oversees all UK insolvencies, with access to records of affected debtors (80,000+ annually).
**8. Stop It Now! (Represents Vulnerable Individuals)**
– **Role**: Supports vulnerable individuals, including those facing financial distress from debt, which may overlap with insolvency victims . Can reach at-risk groups.
– **Contact Details**:
– Phone: 0808 1000 900 (helpline, 9am–9pm Mon–Thu, 9am–5pm Fri)
– Email: help@stopitnow.org.uk
– Address: Stop It Now!, 2 Birch House, Harris Business Park, Hanbury Road, Stoke Prior, Bromsgrove B60 4DJ
– **How to Reach**: Email help@stopitnow.org.uk, explaining how economic pressures from national debt exacerbate financial vulnerability. Request anonymized outreach to clients for class action.
– **Why Effective**: Reaches vulnerable individuals who may align with debtor victims, with a trusted helpline.
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### Challenges and Limitations
– **Privacy Laws**: GDPR and DPA 2018 prevent accessing individual names/emails without consent . Associations must handle outreach anonymously to comply.
– **FOIA Constraints**: Personal data (e.g., insolvency register details) is exempt under FOIA section 23/41 . Only anonymized or non-confidential data can be requested.
– **Data Availability**: No public database lists specific victims of national debt mismanagement. The Individual Insolvency Register () removes records within 3 months of case closure, limiting historical data.
– **Establishment Narrative**: Official sources (e.g., HM Treasury, DMO) may downplay mismanagement or GEMM collusion, per NAO critiques (SEARCHLINK 3). Critical analysis of “nationaldebt.cocoo.uk” and “TI_ BORs.pdf” counters this by highlighting opacity and negligence.
– **Future Victims**: Identifying future taxpayers is speculative, but associations like Citizens Advice can engage younger demographics through outreach campaigns.
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### Strategy to Reach Victims
To build the class action without individual contact details:
– **Partner with Associations**: Email each listed organization with a tailored case summary, emphasizing public interest (transparency, accountability) and victim impact. Request anonymized surveys or opt-in campaigns to identify affected members.
– **Leverage Legal Channels**: Engage solicitors (e.g., via Law Society, info@lawsociety.org.uk) to advertise the class action to clients affected by debt or economic issues, per .
– **Public Campaign**: Use media or platforms like X to post case details (anonymized, per GDPR), directing potential victims to a secure website (e.g., contact@cocoo.uk) for opt-in. Cite “HOW 2 SELL MY LITIGATION.txt” for marketing strategies.
– **Insolvency Data**: Request anonymized insolvency statistics from the Insolvency Service to quantify debtor victims, supporting case scale for buyers like Fortress.
– **Critical Narrative**: Highlight DMO’s failure to disclose BO data and GEMM collusion (per CMA 2019, “TI_ BORs.pdf”) in outreach to counter establishment claims of sound management.
This approach ensures legal compliance, maximizes reach through trusted channels, and strengthens the case’s evidence base, enhancing its appeal to investors. If you need a draft email for a specific association or further guidance on outreach, let me know!
CAMPAIGN
Our first stage is to use the campaign to manufacture a recognised and unavoidable “problem” within the target public bodies. The goal is to make the ongoing administrative and market failures we have identified so visible and politically damaging that the status quo becomes untenable. We will achieve this by systematically presenting our evidence-based findings to the bodies with oversight responsibilities, most notably the Public Accounts Committee in the UK and the EU’s Committee on Budgetary Control. Our reports on the gilt market cartel and the government’s fiscal mismanagement will provide the perfect foundation for their inquiries. This, combined with persistent and targeted media coverage and the mobilisation of stakeholders who can attest to the harm caused, will create an operational imperative for senior officials to act. They will be forced to formally acknowledge a “need” for external expertise to solve the very problem we have defined. Our campaign’s objective is not to ask them to hire us, but to compel them to create a procurement requirement that we are uniquely positioned to fulfil.
The second stage is our tactical point of entry. As you have correctly identified, aiming for a small, below-threshold contract is the most effective way to bypass a lengthy and competitive initial tender process. We will craft an Unsolicited Proposal for a tightly scoped “Fiscal Integrity Scoping Study” at a fixed price designed to fall just below the threshold for a full public procurement, for instance, under ten thousand pounds. Our justification for a direct award will be based on our unparalleled and proprietary expertise. The argument will be firm: our deep knowledge of the specific infringements, combined with our unique analytical frameworks, means that no other supplier can deliver this initial, foundational analysis. A competitive process for such specialised scoping work would be a false economy, and we are the only logical choice to provide this initial assessment.
The third stage is the execution of this strategy through a detailed and professional Statement of Work within our Unsolicited Proposal. This document will be our primary tool for demonstrating our competence and securing the initial contract. It will clearly define the problem we are solving, referencing their specific vulnerabilities that our campaign has brought to light. It will outline our proposed solution, showcasing our expert team and proprietary methodologies. It will detail a list of specific, measurable deliverables for the scoping study, along with a clear timeline and a fixed price. Crucially, the proposal will conclude by stating our readiness to immediately engage with their commercial department to formalise the agreement under standard government service contract terms. By successfully delivering on this initial small contract, we will establish an undeniable track record and an inside relationship, making our consortium the incumbent and most credible bidder for the larger, more substantial procurement process that must inevitably follow to implement the full solution. This is our clear and logical path to victory.
The core of the model campaign is a phased approach designed to build a narrative, establish credibility, and apply targeted pressure. Our first phase will be the “Factual Foundation.” This involves publishing our initial, detailed investigative report, which we will call the “Fiscal Integrity Audit.” This document will focus exclusively on the proven infringement by the Gilt-Edged Market Makers, leveraging the CMA’s findings. It will be professionally designed and distributed to a pre-vetted list of financial journalists, regulators, and key institutional investors. The goal of this phase is to establish COCOO as a credible, evidence-based authority on this specific issue before broadening the argument.
The second phase is “Widening the Lens.” Here, we will connect the specific harm of the gilt cartel to the wider context of administrative failure. We will publish a second report, focusing on the tort claim, detailing the fiscal risks from the debt structure and the lack of transparency in government accounting. This report will be aimed at political editors, public accounts committees, and taxpayer advocacy groups. The narrative will shift from “market rigging” to a “systemic failure of stewardship,” showing how the taxpayer has been harmed from multiple angles.
The third phase, “The Human Story,” involves moving from reports to relatable content. We will partner with business associations and consumer groups to create and pitch case studies to the media. This means finding a small business owner whose expansion plans were thwarted by high capital costs, or a family struggling with inflation. These stories, presented as short videos and articles, will be pitched to national news outlets and lifestyle sections to make the economic harm tangible and emotionally resonant for the public. This phase is crucial for building the widespread public support needed to pressure policymakers.
To execute the outreach for this campaign—contacting potential class members, defendants for mediation offers, and partners for our USP project—we need effective but affordable tools. While LinkedIn Sales Navigator is powerful, there are several more budget-friendly alternatives that can achieve our goals.
One strong alternative is Apollo.io. It has a large B2B database and offers a generous free tier that provides a significant number of search credits and direct email reveals per month. This would allow us to identify and obtain contact information for legal counsel at the defendant banks, investment managers at pension funds, and policy heads at trade associations without any initial financial outlay. Its search filters are robust, allowing us to target individuals by company, job title, and location.
Another excellent option is Hunter.io. While its primary function is finding email addresses associated with a specific company domain, it is extremely cost-effective and can be used in a targeted way. Once we identify a target company, we can use Hunter to find the likely email format and specific contacts within their legal or investment teams. It also offers a free monthly plan.
For broader-scale prospecting and outreach management, platforms like HubSpot and Zoho CRM offer free-forever plans. While they don’t have the vast contact database of Sales Navigator, their free CRM allows us to track all our communications, manage our pipeline of potential claimants and partners, and organize our campaign outreach systematically. We can import contacts found through tools like Apollo or Hunter into these free CRMs to manage the engagement process.
By combining the free tiers of a data provider like Apollo.io with a free CRM like HubSpot, we can create a powerful and highly cost-effective outreach system. This will enable us to systematically contact all the key parties in our case—from the general counsel of the banks we are challenging to the investment committees of the pension funds we seek to represent—without straining our budget.
Our media campaign will be structured around a single, unifying narrative: “A Breach of Trust: How Market Rigging and State Negligence Are Costing Britain Its Future.” This powerful theme connects the specific, proven illegality of the Gilt-Edged Market Makers’ cartel with the broader, systemic failure of public bodies to manage the nation’s finances. It reframes the issue from a complex economic debate into a clear story of public and consumer interest being undermined from two sides. Following the model provided, our campaign will be executed in targeted phases to build momentum and pressure.
The first phase, “The Smoking Gun,” will focus exclusively on the Competition and Markets Authority’s finding of infringement against the banks. This is our entry point—a simple, undeniable story of a powerful cartel rigging a critical market. We will use targeted press releases and briefings to financial journalists to highlight the scale of the wrongdoing and introduce our follow-on damages claim, positioning COCOO as the champion for the victims.
The second phase, “Connecting the Dots,” will broaden the narrative. We will publish a detailed investigative report, our “Fiscal Accountability Audit,” which lays out the evidence for our tort claim. This report will detail the administrative failures—the reckless exposure to inflation via index-linked gilts, the unmanaged costs of Quantitative Tightening, and the failure of transparent accounting. The campaign message will be that the banks’ collusion did not happen in a vacuum; it occurred within a market negligently overseen by public bodies who were simultaneously failing in their own duties.
The third phase, “The Human Cost,” will make the consequences tangible. We will partner with consumer advocacy groups and business associations to release stories of real people and businesses harmed by the cost-of-living crisis and the “crowding out” of investment. This phase is about translating the abstract concept of fiscal mismanagement into the concrete reality of struggling families and shuttered businesses.
To gather the prospective class members for our tort claim, we will create a central online hub. This will be a dedicated campaign website, for example UKPublicInterestClaim.org.uk. This site will serve as the single point of truth for the campaign, explaining the legal basis of our claim in clear language and providing a simple, secure portal for individuals, businesses, and organisations to register their support and formally join the claimant group.
Our outreach to this class will be methodical. We will directly engage with key representative bodies who have locus standi—the legal standing—to represent their members’ interests. For consumers, this means formally approaching organisations like Which? and Citizens Advice. For the business community, we will engage with the Confederation of British Industry (CBI) and the Federation of Small Businesses (FSB). For taxpayers, we will reach out to groups like the TaxPayers’ Alliance. Our pitch to them will be simple: we have established the legal grounds for a powerful claim to seek redress for the harms your members have suffered; join us as a lead claimant to champion their cause.
To drive traffic to our hub and build public momentum, we will launch a coordinated social media campaign.
On X (formerly Twitter), our campaign will operate under a dedicated handle, such as @UKClaim, and use targeted hashtags like #UKDebtScandal and #GiltCartelClaim. The content will be fast-paced and evidence-based, using infographics to explain complex issues like the cost of QT losses and sharing links to media coverage. We will actively engage with journalists, economists, and politicians to inject our narrative into the public debate.
On LinkedIn, our approach will be more detailed and professional. We will publish long-form articles explaining the legal and economic reasoning behind our claims, targeting professionals in the legal, financial, and public sectors. We will use this platform to connect with potential expert witnesses and partners for our consortium, building a visible network of credible support. A dedicated LinkedIn page for the campaign will serve as our professional front.
On Meta’s platforms, Facebook and Instagram, our focus will be on human-centric storytelling. We will use short, impactful video testimonials from small business owners and budget-conscious families, explaining in their own words how the cost-of-living crisis has affected them. We will use paid, targeted advertising to ensure these powerful stories reach a massive audience across the UK, building the widespread public awareness and anger necessary to create an environment where legal and political action becomes unavoidable.