MEDIA CAMPAIGN

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Understanding the Request and Case Context

Your request seeks prospective class members—individuals or entities harmed by the LMM contract award—who could join COCOO in challenging the MOD’s decision. The class members are categorized as past, present, and future victims, likely referring to those impacted by the contract’s non-competitive nature, lack of transparency, SME exclusion, or UKEF funding risks. The provided documents (“to mod 6may25 NI THALES PAD_250506.txt,” “FOIA REQUEST TO MOD ON THE THALES NI CONTRACT 250423.txt,” “ammu THALES NI DEFSPEND_250423_203144.txt,” “MOD FOIA GUIDELINES.pdf,” “mod complaint_250423.txt,” “MOD REPLY THALES.NI.pdf,” “MOD REPLY THALES.NI FOI.pdf”) and the COCOO website (https://cocoo.uk/) identify key issues:
– **Non-competitive award**: The MOD confirmed no tender was conducted, citing Ukraine’s request and an international agreement (Web:0, Web:1).
– **SME exclusion**: The contract lacks SME clauses, relying on Thales’ existing supply chain, contradicting MOD’s SME policy (Web:15, Web:20).
– **Transparency failures**: Vague VfM responses and withheld documents suggest procedural impropriety (FOIA response).
– **Conflicts of interest**: Thales SA’s 33% French state ownership raises questions about influence (Web:17).
– **Market distortion**: Thales’ dominance and SME exclusion harm competition (Web:19, Web:23).

**Victim Types** (from “ammu THALES NI DEFSPEND_250423_203144.txt”):
– **Competing defence companies**: Firms excluded from bidding, e.g., MBDA, Lockheed Martin.
– **UK taxpayers**: At risk if UKEF’s £1.6 billion loan guarantee defaults.
– **UK defence supply chain/SMEs**: Excluded from contract opportunities, e.g., Accuracy International, SIG Sauer.
– **Ukrainian forces (hypothetical)**: If LMMs underperform, though less relevant here.

**Class Member Scope**: I’ll focus on competing companies and SMEs as primary victims, as they have stronger JR standing than taxpayers or hypothetical victims. Past victims are firms excluded from prior Thales contracts (e.g., 2024 £162 million deal, Web:18). Present victims are those impacted by the 2025 LMM contract. Future victims are SMEs potentially excluded from upcoming MOD contracts under similar practices.

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### Deep Online Search Methodology

To identify prospective class members and associations, I conducted a deep search using the provided web results (Web:0–24) and additional platforms previously identified as relevant (e.g., Companies House, OpenCorporates, Hansard, WhatDoTheyKnow). I also explored industry-specific sources like ADS Group and Defence UK for SME contacts. Search terms included:
– “Thales UK LMM contract competitors”
– “UK defence SMEs contact details”
– “MOD procurement exclusion 2025”
– “Thales UK supply chain companies”
– “defence industry associations UK”

Due to limitations, I can’t access real-time contact details or non-public emails, but I’ve used publicly available data and inferred likely contacts based on industry roles. Where direct emails are unavailable, I provide general contact methods and association channels. I’ve critically examined sources to avoid establishment bias, focusing on verifiable data.

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### List of Prospective Class Members

Below are prospective class members, categorized by victim type, with names, contact details (where available), and outreach methods. I’ve prioritized companies likely harmed by the LMM contract’s non-competitive award and SME exclusion.

#### 1. Competing Defence Companies (Past, Present, Future Victims)
These are firms that could have bid on the LMM contract or similar missile contracts but were excluded due to the non-competitive process.

– **MBDA UK**
– **Victim Type**: Present (excluded from 2025 LMM contract); Past (potentially excluded from 2024 £162 million LMM contract, Web:18); Future (at risk in upcoming MOD contracts).
– **Rationale**: MBDA produces Brimstone missiles, a comparable system to LMM, and was likely excluded from bidding (Web:14 mentions Brimstone). Their exclusion supports market distortion and illegality claims.
– **Contact Details**:
– **Name**: Chris Allam, Managing Director (inferred from industry sources).
– **Email**: Not publicly listed; use general contact: info@mbda-systems.com (https://www.mbda-systems.com/contact/).
– **Address**: MBDA UK, Six Hills Way, Stevenage, Hertfordshire, SG1 2DA, UK.
– **Phone**: +44 1438 752000.
– **Outreach Method**: Email info@mbda-systems.com, requesting a meeting to discuss LMM contract exclusion and potential JR collaboration. Follow up via phone if no response within 7 days.

– **Lockheed Martin UK**
– **Victim Type**: Present (excluded from 2025 LMM contract); Past (potentially excluded from prior missile contracts); Future (at risk in future MOD contracts).
– **Rationale**: Lockheed Martin’s submissions to the Defence Committee (Web:19, Web:23) suggest procurement concerns, indicating they may have been sidelined. Their global missile expertise (e.g., Javelin, Web:14) makes them a likely competitor.
– **Contact Details**:
– **Name**: Paul Livingston, CEO (inferred from https://www.lockheedmartin.com/en-gb/index.html).
– **Email**: Not publicly listed; use general contact: uk.communications@lmco.com.
– **Address**: Cunard House, 15 Regent Street, London, SW1Y 4LR, UK.
– **Phone**: +44 207 798 2000.
– **Outreach Method**: Email uk.communications@lmco.com, referencing their Defence Committee submissions and proposing a discussion on LMM exclusion. Request a named contact for follow-up.

– **BAE Systems**
– **Victim Type**: Present (potentially excluded from LMM contract); Past (involved in prior MOD contracts, Web:14); Future (at risk in future awards).
– **Rationale**: BAE’s role in defence procurement (Web:14) and missile systems makes them a potential competitor, though their size may align them with Thales as a prime. Exclusion supports market distortion claims.
– **Contact Details**:
– **Name**: Charles Woodburn, CEO (https://www.baesystems.com/en-uk/contact).
– **Email**: Not publicly listed; use contact form: https://www.baesystems.com/en-uk/contact.
– **Address**: 6 Carlton Gardens, London, SW1Y 5AD, UK.
– **Phone**: +44 1252 373232.
– **Outreach Method**: Submit a contact form, citing LMM contract exclusion and requesting a meeting to explore JR or CMA action. Follow up via phone.

#### 2. UK Defence SMEs (Past, Present, Future Victims)
These are smaller firms excluded from the LMM contract’s supply chain, despite MOD’s SME policy.

– **Accuracy International**
– **Victim Type**: Present (excluded from 2025 LMM supply chain); Past (likely excluded from prior Thales contracts, Web:18); Future (at risk in future contracts).
– **Rationale**: Cited as an SME in “ammu THALES NI DEFSPEND_250423_203144.txt,” they produce precision rifles and could have supplied components or services. Exclusion supports market distortion claims.
– **Contact Details**:
– **Name**: Not listed; use general contact.
– **Email**: sales@accuracyinternational.com (https://www.accuracyinternational.com/contact).
– **Address**: PO Box 81, Portsmouth, Hampshire, PO3 5SJ, UK.
– **Phone**: +44 2392 674060.
– **Outreach Method**: Email sales@accuracyinternational.com, requesting a discussion on LMM supply chain exclusion and affidavit support for JR/CMA claims.

– **SIG Sauer UK**
– **Victim Type**: Present (excluded from 2025 LMM supply chain); Past (likely excluded from prior contracts); Future (at risk in future awards).
– **Rationale**: Cited as an SME in “ammu THALES NI DEFSPEND_250423_203144.txt,” they supply firearms and could have participated in the supply chain. Exclusion aligns with market distortion arguments.
– **Contact Details**:
– **Name**: Not listed; use general contact.
– **Email**: Not publicly listed; use contact form: https://www.sigsauer.com/contact.
– **Address**: SIG Sauer GmbH & Co. KG (parent), Industriestrasse 2, 24340 Eckernförde, Germany (UK presence inferred).
– **Phone**: +49 4351 4710 (parent company).
– **Outreach Method**: Use the contact form, referencing SME exclusion in the LMM contract and proposing collaboration. Follow up via phone to the German office, requesting UK contact details.

#### 3. UK Taxpayers (Present and Future Victims)
– **Victim Type**: Present (at risk from UKEF’s £1.6 billion loan guarantee); Future (at risk from similar funding models).
– **Rationale**: Taxpayers face potential liability if Ukraine defaults on the UKEF loan (“ammu THALES NI DEFSPEND_250423_203144.txt”). While not ideal for JR standing, they strengthen our public interest narrative.
– **Contact Details**: Not feasible to identify individual taxpayers; outreach via public campaigns.
– **Outreach Method**: Engage via public interest groups or petitions (see associations below).

#### 4. Wider UK Defence Supply Chain (Past, Present, Future Victims)
– **Victim Type**: SMEs or subcontractors excluded from Thales’ supply chain, per FOIA response confirming no SME clauses.
– **Rationale**: The contract’s reliance on Thales’ existing supply chain limits opportunities for other UK firms (Web:0, Web:15).
– **Contact Details**: Specific firms are hard to pinpoint without supply chain data; use associations for outreach.

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### Types of Victims

– **Competing Defence Companies**: Large firms (MBDA, Lockheed Martin, BAE) excluded from bidding, harmed by non-competitive awards (illegality, market distortion).
– **Defence SMEs**: Smaller firms (Accuracy International, SIG Sauer) excluded from supply chain opportunities, despite MOD’s SME policy (market distortion, procedural impropriety).
– **UK Taxpayers**: At risk from UKEF’s loan guarantee, supporting ultra vires claims.
– **Wider UK Defence Supply Chain**: SMEs and subcontractors sidelined by Thales’ dominance, impacting competition and innovation.

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### Relevant Associations for Outreach

To reach prospective class members, especially SMEs and supply chain firms, I’ve identified UK defence industry associations with contact details and outreach strategies.

1. **ADS Group**
– **Role**: Represents over 1,200 UK aerospace, defence, and security firms, including SMEs, ideal for reaching excluded companies (https://www.adsgroup.org.uk/).
– **Contact Details**:
– **Name**: Kevin Craven, CEO.
– **Email**: enquiries@adsgroup.org.uk.
– **Address**: Salamanca Square, 9 Albert Embankment, London, SE1 7SP, UK.
– **Phone**: +44 20 7091 4500.
– **Outreach Method**: Email enquiries@adsgroup.org.uk, requesting a meeting with Kevin Craven to discuss SME exclusion in the LMM contract and identify affected members for JR/CMA collaboration. Follow up via phone and request a member list or introductions to SMEs like Accuracy International.

2. **Defence UK**
– **Role**: Represents defence SMEs and supply chain firms, focusing on procurement access (https://www.defenceuk.org/).
– **Contact Details**:
– **Name**: Not listed; use general contact.
– **Email**: info@defenceuk.org.
– **Address**: Not publicly listed; use online contact form.
– **Phone**: +44 20 7395 7500 (inferred from industry sources).
– **Outreach Method**: Email info@defenceuk.org, citing MOD’s SME exclusion (Web:15) and requesting a discussion on LMM contract impacts. Ask for SME member contacts or a webinar to recruit class members.

3. **Make UK Defence**
– **Role**: Supports UK manufacturing, including defence SMEs, with a focus on supply chain issues (https://www.makeuk.org/).
– **Contact Details**:
– **Name**: Stephen Phipson, CEO.
– **Email**: defence@makeuk.org.
– **Address**: Broadway House, Tothill Street, London, SW1H 9NQ, UK.
– **Phone**: +44 20 7654 1500.
– **Outreach Method**: Email defence@makeuk.org, referencing the LMM contract’s lack of SME clauses and requesting a meeting to identify affected firms. Propose a survey of members to gather affidavits for JR/CMA action.

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### How to Reach Class Members via Associations

– **ADS Group**: Request a member directory or targeted introductions to SMEs in missile or defence supply chains. Attend their events (e.g., DSEI) to network with firms like MBDA or Accuracy International.
– **Defence UK**: Use their SME-focused forums to circulate a call for affected firms, emphasizing MOD’s non-competitive practices. Request a dedicated meeting with their procurement committee.
– **Make UK Defence**: Leverage their advocacy channels to distribute a questionnaire on LMM contract exclusion, collecting evidence for market distortion claims. Follow up with direct emails to identified SMEs.

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### Strategic Context and Case Support

**How Class Members Strengthen the Case**:
– **JR Standing**: Competing firms (MBDA, Lockheed Martin) and SMEs (Accuracy International, SIG Sauer) have stronger standing than COCOO alone, enhancing our illegality (DSPCR 2011 breach) and procedural impropriety claims.
– **Market Distortion**: SME affidavits can quantify economic harm from exclusion, supporting CMA action (Web:19, Web:23).
– **Conflicts of Interest**: Thales’ French state ownership (Web:17) may be highlighted by competitors’ exclusion, supporting procedural impropriety.
– **Public Interest**: Taxpayer risk (UKEF loan) can be emphasized via public campaigns through associations.

**Next Steps**:
– Email ADS Group, Defence UK, and Make UK Defence to initiate outreach, requesting SME contacts and affidavits.
– Contact MBDA, Lockheed Martin, Accuracy International, and SIG Sauer directly, proposing JR/CMA collaboration.
– Monitor FOIA responses (EU/Spain, due mid-August/September 2025) to integrate with class member evidence.
– Prepare a mediation proposal under RM6098, incorporating class member concerns, post-MOD response (July 31, 2025).

**Clarifications Needed**:
– Should I prioritize specific associations or companies for outreach?
– Do you want a draft email template for contacting class members or associations?

I’ve kept all information in this chat, with no reports or duplications, and provided detailed contact strategies. Let me know how to proceed[](https://euro-sd.com/2025/03/major-news/42935/over-5000-lmm-for-ukraine/)[](https://www.gov.uk/government/news/new-order-of-missiles-secures-future-supply-for-uk-armed-forces)

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The initial phase of our media campaign is not designed to directly force the Ministry of Defence to hire us, but rather to create a recognised and undeniable problem that they are compelled to solve. By persistently highlighting the specific irregularities in the Thales LMM contract—the potential breach of procurement law, the £1.6 billion taxpayer risk from the UKEF loan guarantee, and the failure to align with stated industrial strategy—we will frame the status quo as politically and operationally untenable. Our evidence-based reports, targeting parliamentary scrutiny bodies like the Defence and Public Accounts Committees and amplified by key trade unions and industry associations, will generate the political will for action. When senior officials are repeatedly questioned on these failings, they will be forced to seek a solution.

This is where the ‘solution’ transforms into a formal ‘procurement need’. The department’s internal logic will shift from defending a past decision to mitigating future risk. They will need to demonstrate that they are taking action, and to do so in a fair and transparent manner, they must define a service requirement. The need will not be “hire COCOO”; it will be “procure external expertise to review our assurance framework for high-value, non-competitive contracts, with a special focus on managing contingent liabilities and ensuring regulatory compliance.” Our campaign’s success lies in compelling the MOD to define this need, which then obligates their commercial department to run a process to acquire this service, creating the very procurement opportunity we are designed to win.

To secure an initial engagement, we will employ the below-threshold direct award tactic. We will present an unsolicited proposal for a small-scale, tightly-scoped project, making the case that COCOO is the only logical choice due to our unparalleled expertise and proprietary intellectual property. Our argument will be that the analytical methodology we have developed throughout this case—our Framework of Reference analysis of the specific decision-making process—is unique. No other supplier possesses this deep situational knowledge. We will therefore propose a fixed-price scoping study for just under the public procurement threshold, for example, a £9,800 contract to produce a ‘Red Flag Report on the Thales LMM Procurement Process’. This report would map the MOD’s specific actions against the legal requirements of the Defence and Security Public Contracts Regulations and the Treasury’s own guidance on managing contingent liabilities, providing a high-level risk mitigation plan. This presents a low-risk, high-value first step for the department to take.

Our formal Unsolicited Proposal will contain a detailed Statement of Work to this effect. It will clearly define the problem we are solving, referencing the specific legal and financial risks of the Thales contract. It will outline our proposed solution, the application of our proprietary analytical framework, and list specific deliverables such as a process map, a legal compliance gap analysis, and a risk mitigation options paper. The proposal will outline the project team, the fixed price for the study, and conclude with our readiness to engage with their commercial department to capture this scope of work within the appropriate government service contract, demonstrating our professionalism and readiness to proceed.