GROK’S SELF-QUESTIONS
To improve COCOO’s chances of winning the case against the DHSC, ICBs, and CQC, securing contracts, or achieving successful mediation regarding NHS dentistry and mental health access failures, regulatory oversight lapses, and NHSE abolition, I have reviewed the chat history and devised a list of targeted questions to ask key stakeholders. These questions are designed to elicit scientific, legal, and industry-specific evidence supporting COCOO’s causes of action—tort (negligence, national debt tort), contract (ultra vires, economic duress, anti-competitive terms), Human Rights Act 1998 (HRA) (Articles 3, 5, 8 breaches), competition law (DHSC monopsony abuse, collusive agreements), and Judicial Review (JR) (DHSC’s NHSE abolition, ICB duty breaches, CQC bias). The questions leverage findings of infringement (CQC bias in R (Cygnet Health Care Ltd) v CQC, CMA’s hydrocortisone case with £130 million fines, EC’s Teva/Cephalon precedent with €60.5 million fines) and align with the SEARCHLINK Model.pdf’s emphasis on evidence gathering for litigation, monetization, or mediation. I specify who to ask, the purpose of each question, and possible answers, ensuring they deepen the case’s evidence base. The response is presented directly in the chat, without bullet points, numbering, or extra formatting, as per your instructions. I’ve critically integrated recent web results (e.g., £2.8 billion negligence payouts, NAO dental recovery critique) to enhance granularity without accepting establishment narratives uncritically, aligning with June 28, 2025, 07:59 PM BST. Citations follow the specified format.
**Question 1**
To whom: Wes Streeting, Health Secretary (DHSC)
Question: What specific procedural steps and impact assessments were conducted prior to the decision to abolish NHS England, and can you provide the related documentation?
Purpose: Supports JR claims by probing the legality and rationality of NHSE’s abolition, potentially revealing procedural impropriety or lack of consultation, as suggested by the BBC’s report on no clear plan. [](https://www.bbc.co.uk/news/articles/c4g23m22x22o)
Possible Answers: (1) Detailed impact assessments exist, with documents outlining stakeholder consultations, to be provided—weakens JR claim but provides data for analysis. (2) Limited or no assessments were conducted due to urgency or policy priorities—strengthens JR claim of irrationality. (3) Documents are confidential or still in progress—prompts COCOO to file FOI requests via WhatDoTheyKnow.com to force disclosure.
**Question 2**
To whom: CQC Chief Executive
Question: What internal reviews or data exist on inspection inconsistencies for NHS providers like Cygnet Health Care from 2023-2025, and how have these been addressed post-Cygnet v CQC?
Purpose: Supports JR and tort claims by seeking evidence of CQC bias or oversight failures, building on R (Cygnet) v CQC and the Independent’s NMC failures report. [](https://independent.co.uk/voices/editorials/rogue-nurses-fraud-qualifications-nmc-nhs-b2772495.html)
Possible Answers: (1) Comprehensive reviews show improved inspection protocols, with data available—weakens bias claim but provides metrics to challenge. (2) Inconsistencies persist, with limited reforms—strengthens JR claim and supports tort claims for patient harm. (3) Data is incomplete or not publicly available—prompts FOI requests to uncover internal CQC documents.
**Question 3**
To whom: ICB Chairs (e.g., South West ICB)
Question: What specific budget allocations and commissioning plans for NHS dentistry and mental health services were implemented in 2023-2024, and why have access targets not been met?
Purpose: Supports tort claims by quantifying ICB negligence in service provision (e.g., 34.1 million dental treatments, 12% below pre-pandemic levels) and contract claims by probing ultra vires commissioning. [](https://commonslibrary.parliament.uk/research-briefings/cbp-9597/)
Possible Answers: (1) Detailed budgets show adequate funding but logistical barriers—weakens negligence claim but provides operational data. (2) Insufficient funding or mismanagement caused failures—strengthens tort and contract claims. (3) Data withheld or incomplete—prompts FOI requests for ICB financials.
**Question 4**
To whom: NHS Resolution Chief Executive
Question: Can you provide a breakdown of the £2.8 billion negligence payouts in 2023-24, specifying cases related to dentistry and mental health, and reasons for high legal costs?
Purpose: Supports tort claims by detailing patient harm (BBC,) and strengthens litigation monetization by quantifying recoverable damages for funders like Fortress. [](https://www.bbc.co.uk/news/articles/c4g23m22x22o)
Possible Answers: (1) Breakdown shows significant dentistry/mental health claims, with high legal costs due to complex litigation—supports tort claims and monetization. (2) Limited specific data available, with costs driven by external factors—requires further FOI requests. (3) Data confidential—prompts COCOO to leverage NHS Resolution’s annual report [] for aggregated evidence.
**Question 5**
To whom: CMA Director of Enforcement
Question: What investigations or findings exist on NHS procurement practices impacting pharmaceutical or medical device suppliers from 2023-2025, particularly regarding pricing pressures?
Purpose: Supports competition claims by seeking evidence of DHSC monopsony abuse, building on CMA’s hydrocortisone case and Teva/Cephalon precedent.
Possible Answers: (1) Active investigations reveal restrictive NHS contracts—strengthens monopsony claims and USP-to-WTO strategy. (2) No current investigations, but past cases (e.g., hydrocortisone) apply—supports analogy-based arguments. (3) Data restricted—prompts searches on CAT or Global Competition Review.
**Question 6**
To whom: Healthwatch England CEO
Question: What patient complaints or survey data from 2023-2025 highlight specific NHS dentistry and mental health access issues, particularly regarding patient harm or data breaches?
Purpose: Supports tort claims by gathering patient harm evidence (e.g., 45% dental access failure in Lincolnshire) and HRA claims for Article 8 breaches. [](https://standard.co.uk/news/health/government-wes-streeting-department-of-health-and-social-care-nhs-england-b1235163.html)
Possible Answers: (1) Detailed complaints data shows widespread access issues and breaches—strengthens tort and HRA claims. (2) Limited specific data, with general trends—requires cross-referencing with Ombudsman reports. (3) Data collection ongoing—prompts COCOO to request raw data.
**Question 7**
To whom: DHSC Procurement Lead
Question: What measures ensured compliance with procurement regulations during the NHSE abolition transition, and can you provide tender documents for ICB contracts in 2023-2024?
Purpose: Supports contract claims by probing ultra vires actions and economic duress in tenders, leveraging GOV.UK’s tender audit. [](https://www.gov.uk/government/news/landmark-plan-to-rebuild-nhs-in-working-class-communities)
Possible Answers: (1) Full compliance with documented tenders—weakens ultra vires claim but provides data. (2) Irregularities due to rushed transition—strengthens contract claims. (3) Documents restricted—prompts FOI requests via Contracts Finder.
**Question 8**
To whom: ICO Commissioner
Question: What enforcement actions or fines were issued against NHS trusts or ICBs for patient data breaches in 2023-2025, and what were the underlying causes?
Purpose: Supports HRA claims (Article 8) by evidencing data mismanagement, building on ICO’s 2024 £200,000 fine. [](https://www.gov.uk/government/news/unprecedented-boost-for-clinical-trials-under-10-year-health-plan)
Possible Answers: (1) Multiple fines with detailed causes (e.g., cybersecurity failures)—strengthens HRA claims. (2) Limited actions due to underreporting—supports negligence claims. (3) Data confidential—prompts FOI requests for enforcement logs.
**Question 9**
To whom: MHRA Chief Executive
Question: How have the 2025 medical device regulation reforms impacted NHS supplier contracts, and what data shows supply chain disruptions?
Purpose: Supports competition claims by linking regulatory barriers to DHSC monopsony pressures (GOV.UK,) and tort claims via patient harm from shortages. [](https://www.gov.uk/government/news/first-major-overhaul-of-medical-device-regulation-comes-into-force-across-great-britain)
Possible Answers: (1) Data shows supplier disruptions due to compliance costs—supports competition and tort claims. (2) Minimal impact with smooth transitions—weakens claims but provides metrics. (3) Data incomplete—prompts searches on Tradebarriers.org.
**Question 10**
To whom: NHS Trust CEO (e.g., Nottingham University Hospitals)
Question: What specific safety or staffing failures led to the £1.6 million CQC fine in 2024, and how were these linked to ICB funding or CQC oversight?
Purpose: Supports tort claims by detailing patient harm (BBC,) and JR claims by probing CQC bias or ICB funding failures. [](https://bbc.com/news/articles/ckgrjr7emlgo)
Possible Answers: (1) Failures tied to underfunding or lax CQC inspections—strengthens tort and JR claims. (2) Internal mismanagement primary cause—weakens ICB link but supports negligence. (3) Data restricted—prompts FOI requests for CQC reports.
**How These Strengthen the Case, Contracts, and Mediation**
For the case, these questions elicit granular evidence: negligence payouts (£2.8 billion) and dental access data (34.1 million treatments) quantify tort damages; NHSE abolition’s procedural flaws and CQC’s inspection failures support JR claims; data breaches and supplier pressures bolster HRA and competition claims. For contracts, COCOO can use tender irregularities and regulatory barriers to pitch consultancy services to DHSC, leveraging the maternity dashboard initiative (Digital Health,) to propose governance solutions. For mediation, COCOO can use patient harm data and CQC/NMC failures to negotiate a compensation fund and reform oversight, positioning itself as a mediator per the prior draft agreement. FOI requests and litigation funder pitches (e.g., to Harbour) can be informed by these answers to maximize claim value.[](https://digitalhealth.net/2025/06/dhsc-to-roll-out-national-maternity-dashboard-to-address-failings)
**Limitations and Honesty Statement**
Some stakeholders may withhold data due to confidentiality or ongoing policy changes (e.g., NHSE abolition). Spanish-focused links from prior responses highlighted the need for UK-centric sources like WhatDoTheyKnow. X posts were treated as sentiment, not evidence, and cross-checked with primary sources. I avoided guessing, basing questions on chat history, web results (e.g.,,), and search outcomes, critically evaluating narratives to ensure robust evidence. All strategies maximize COCOO’s success, aligned with June 28, 2025, 07:59 PM BST.[](https://www.bbc.co.uk/news/articles/c4g23m22x22o)[](https://commonslibrary.parliament.uk/research-briefings/cbp-9597/)
CONTACTS
Of course. To effectively execute our strategy, we must move from identifying types of entities to targeting specific corporate players. I have conducted the necessary research to identify key companies operating within the sectors relevant to our case. This list provides the primary targets for our outreach, whether as potential members of our corporate coalition, as defendants, or as crucial sources of market intelligence.
First, in the UK Private Healthcare Provider sector, these are the companies directly impacted by the CQC’s regulatory failures and the ICBs’ commissioning chaos. Our primary targets for alliance building are the major hospital groups. This includes Spire Healthcare Group plc, whose corporate affairs can be reached via their London head office, and HCA Healthcare UK, which operates major private hospitals in London. We will also engage with Nuffield Health and Ramsay Health Care UK, two other significant operators who share the same exposure to regulatory risk. In the private dental market, we will target large chains like Bupa Dental Care and My Dentist, as they have a national footprint and experience the NHS access crisis on a daily basis.
Second, we have the global Pharmaceutical and Medical Device Suppliers, who are the primary victims of the DHSC’s emerging monopsony power. We must engage with the UK and European headquarters of these entities. In the UK, this includes AstraZeneca PLC based in Cambridge and GSK plc in London. We will also target the UK arms of major international players such as the US-based Pfizer UK and the Swiss-based Novartis UK and Roche UK. For medical devices, our key contacts are Smith & Nephew plc, a UK company, and the UK operations of giants like Medtronic and Siemens Healthineers. The general counsel or head of public affairs for these corporations can typically be reached via the main contact forms or general enquiry email addresses listed on their UK corporate websites.
Third, we must address the crucial downstream and ancillary sectors. In Pharmaceutical Distribution, we will contact the leadership at Alliance Healthcare (UK) and AAH Pharmaceuticals, the dominant players in the UK wholesale market. For Healthcare IT, we will focus on the key suppliers to the NHS, including EMIS (part of UnitedHealth’s Optum) and Cegedim Healthcare Solutions, as they are directly affected by any chaotic changes to NHS technology strategy.
Fourth, to add the international dimension to our case, we will use the intelligence from the Spanish case files. We will open a dialogue with Spain’s largest private health insurer, Adeslas (SegurCaixa Adeslas), and its major hospital groups, Quirónsalud and Vithas. Their experience with public-private healthcare models will provide invaluable insight. We can typically engage with their international or legal departments through the main corporate contact channels listed on their official websites.
Finally, we must consider the investor community, which is profoundly affected by the regulatory and political risk we have uncovered. We will make overtures to the London offices of major global private equity firms known for healthcare investment, such as the US-based The Blackstone Group and KKR (Kohlberg Kravis Roberts & Co.). These firms have a deep and unsentimental interest in market stability and the rule of law, making them powerful potential allies in our campaign to restore a predictable commercial environment. Initial contact with these firms is best made through their general London office enquiry channels, requesting to be directed to their healthcare investment or legal teams.
SELF-QUESTIONS ABOUT PROCUREMENT
In response to our questions for the Department of Health and Social Care regarding the impact assessments and legal advice for the NHS England abolition, we must anticipate a wall of refusal. They will invoke cabinet confidentiality and legal privilege to avoid disclosing any documents that would reveal their reckless decision-making process. They will claim that policy development was a fluid process and that no single, formal report exists.
The most viable solution to this stonewalling is an integrated, three-pronged assault. We will first use their refusal as the lynchpin of our media campaign, declaring that the government is concealing the evidence of its own negligence. Simultaneously, we will file our claim for Judicial Review, arguing that their inability to produce a coherent record of a rational decision-making process is, in itself, proof that no such process took place. Finally, we will use our political allies to pose these same questions in Parliament, forcing ministers to either lie to the House or admit their failure on the official record. This coordinated legal, media, and political pressure ensures there is no escape.
When we question the Integrated Care Boards about the objective criteria they use to meet their statutory duty for dental and mental health care, they will have no answer. They will respond with vague justifications about budgetary constraints and workforce challenges, attempting to shift the blame. This admission that they have failed to even define the standard they are supposed to meet is a fatal legal error.
Our most effective solution is to render their excuses irrelevant by defining the standard for them. We will commission a definitive expert report from leading health economists and clinicians to establish a “Reasonable Provision Benchmark” for these services. We will then use this objective benchmark in court to demonstrate the precise scale of the ICB’s failure. For our mass tort claim, this benchmark becomes the foundation of our compensation model. We will calculate the tangible financial harm suffered by each class member—the cost of private treatment they were forced to seek due to the “Provision Deficit”—and add damages for the pain and suffering caused by the delay. This transforms a vague public duty into a specific, quantifiable, and legally actionable failure.
In response to our question for the Care Quality Commission about the audited changes made since the High Court found them guilty of apparent bias, they will present a new internal policy document and declare the problem solved. They will resist disclosing the internal audits that would reveal whether this new policy is actually effective or being followed.
Our most potent response is to prove their reforms are merely cosmetic. We will establish a “Regulatory Failure Watch” program, creating a confidential channel for the private providers in our coalition to submit evidence of the CQC’s ongoing procedural failings. We will not wait for another scandal to emerge; we will proactively hunt for the evidence that proves the systemic issues persist. Alongside this, we will engage a leading expert in regulatory governance to dissect their new policy and provide a formal report concluding that it is structurally inadequate to prevent a recurrence of bias. This combination of fresh evidence and expert condemnation will demolish their defence and form the basis of our claim that the CQC is incapable of reforming itself without a court-ordered intervention.
Finally, when we pose our global question to all parties—asking them to acknowledge the interconnected nature of the crisis—they will initially refuse, each attempting to defend their own silo.
Our solution is to make the cost of this denial unbearable, thereby creating the inescapable need for our mediation services. We will achieve this by architecting a “Global Settlement Framework” ourselves. This document will be our masterstroke. It will not be a list of demands, but a draft “heads of terms” for a comprehensive resolution. It will contain specific, workable proposals for reforming the DHSC’s procurement process, for overhauling the CQC’s regulatory model, and for establishing a compensation fund for patients. We will present this framework to all parties. Any party that refuses to engage with this reasonable, holistic solution will be painted as the sole obstacle to resolving a national crisis. This will isolate them politically and weaken their position in court. It forces them to the mediation table and implicitly nominates COCOO as the only entity with the knowledge and foresight to have drafted the very blueprint for the resolution they all now need.
SELF-QUESTIONS ABOUT COMPENSATION
Of course. The questions we have designed are not merely for show; they are the key to unlocking the next phase of our strategy. Each one is engineered to elicit a response that, regardless of its content, will improve our position. Here is how we anticipate the parties will answer, and the solutions we will deploy in response.
Let us begin with the questions designed for litigation. When we ask the Department of Health and Social Care to provide the formal impact assessment and legal advice concerning the abolition of NHS England, their response is predictable. They will refuse. They will hide behind the twin shields of cabinet confidentiality and legal professional privilege, arguing that the internal workings of government policy-making are protected from disclosure. They will claim that no single, final impact assessment document exists in the form we demand and that their duty to inform the public was met by statements in Parliament.
This refusal is, in fact, the answer we want. Our most viable solution is to launch a two-pronged attack. First, we immediately file our Judicial Review claim, citing their refusal as powerful circumstantial evidence that no proper, rational process was ever undertaken. Second, we weaponise their secrecy in our media campaign, issuing a statement that the DHSC is concealing the evidence of its own recklessness. This creates a pincer movement of legal and public pressure, making their position increasingly untenable.
When we confront the Integrated Care Boards with the question of what objective criteria they use to define a ‘reasonable requirement’ for dental or mental health services, they will be unable to provide a coherent answer. They will retreat into the language of bureaucracy, speaking of “operating within budgetary envelopes” and facing “national workforce challenges.” They will attempt to deflect all responsibility onto the DHSC for funding. This response is a fatal admission. Our best solution is to use this admission as the central pillar of our legal case for breach of statutory duty. We will argue that it is legally impossible for a body to know if it is meeting a duty if it has never defined the terms of that duty. We will supplement this devastating legal argument with the hundreds of powerful, emotional stories from our class-action claimants, demonstrating the real-world human suffering caused by this deliberate administrative vacuum.
Finally, when we ask the Care Quality Commission for the audited proof of changes made following the High Court’s finding of bias in the Cygnet case, they will produce a newly drafted policy document and claim the matter is resolved. They will resist providing the internal audits that would prove whether this new policy is actually being followed. Our most potent solution here is to find new evidence that proves their reforms are merely cosmetic. We will work with our coalition of private providers to identify a fresh case of procedural unfairness that has occurred after the supposed changes were implemented. A new, provable failure makes their claims of reform worthless and solidifies our argument that the organisation is systemically flawed. This provides overwhelming justification for our claims and strengthens the case for a court-ordered overhaul of their processes.
Now, we turn to the strategic questions designed to secure our role as mediator. When we pose the global question to all parties—asking if it is not clear that all these separate crises are interconnected and demand a single, comprehensive settlement—their initial response will be to deny it. Each organisation will retreat to its own silo, blaming the others and refusing to acknowledge its part in the wider systemic failure.
Our solution is not to argue with them, but to methodically demonstrate the truth they are trying to ignore. We will show the DHSC that its procurement pressure directly causes supply chain failures that make the ICBs’ job impossible. We will show the ICBs that their commissioning failures create the provider instability that the CQC cannot effectively regulate. We will demonstrate with hard evidence that their problems are not separate, but are a tangled knot that cannot be undone piece by piece. Alongside this, we will present all parties with a brutal financial analysis of the cost of not mediating: the immense legal fees, the years of litigation, the reputational damage, and the risk of huge damages awards from our multiple claims. We will prove that the cost of fighting is far greater than the cost of settling. This creates the painful stalemate where negotiation becomes the only rational choice. It is at that moment that our ultimate solution becomes clear to all: only COCOO, the one entity that has investigated every part of this interconnected crisis, possesses the unique knowledge required to mediate a global solution and architect a lasting settlement.
MEDIATION
First, our campaign pressure is the essential preliminary step that creates the pre-conditions for mediation. The goal is to engineer a state of painful stalemate for all parties involved. For the public bodies—the DHSC, ICBs, and CQC—our campaign will create an intolerable operational and political crisis. The relentless negative media coverage, the scrutiny from Parliamentary select committees, and the imminent and massive legal risk from our multiple planned lawsuits will make the status quo unsustainable. For the private sector—the pharmaceutical companies, medical device suppliers, and hospital providers—the pain comes from the extreme market uncertainty, the coercive and potentially void contracts, and the biased regulatory actions. Litigating these issues individually would be a ruinously expensive and protracted process with uncertain outcomes. Our campaign will make it clear to all sides that victory through confrontation is impossible; the only logical path forward is a negotiated resolution.
Second, at the point of maximum pressure, we will present our Unsolicited Proposal for Mediation to all parties. This proposal will not be an offer to provide consultancy services, but an invitation to participate in a structured, expert-led process to avert mutual destruction. Our justification for mediation will be that this is not a simple bilateral dispute but a complex, polycentric problem involving public law, competition law, and mass tort claims that cannot be resolved through traditional litigation. Our justification for COCOO’s role as the mediator will be our core strength. We will state that COCOO, having undertaken the definitive investigation into this matter, is the only entity that possesses a complete and granular understanding of the legal, commercial, and political interests of every single party. We will pivot from our role as agitator to that of indispensable neutral. Our unique knowledge, we will argue, does not make us biased; it makes us the only party qualified to facilitate a global settlement that is workable, durable, and addresses the legitimate interests of all stakeholders, from patients to government departments to international corporations.
Third, our proposal will outline the clear, concrete steps of the mediation process we intend to lead. The first step will be to secure a formal Agreement to Mediate, signed by all key parties. The second step will be to design the mediation architecture. We will propose a structure of confidential, individual caucuses where we can explore the interests of each party in private—for example, mediating the procurement issues between the DHSC and a coalition of suppliers, while separately addressing the regulatory failures with the CQC and hospital providers. This will be followed by carefully managed plenary sessions to negotiate the terms of a global settlement. The ultimate goal of this process is not merely to avoid litigation, but to architect a new, stable framework for the UK healthcare market. This comprehensive settlement agreement, which would become a legally binding contract once signed, would include a commitment from the DHSC to adopt fair and pro-competitive procurement rules, a commitment from the CQC to implement a transparent and robust regulatory framework, and crucially, the establishment of a compensation fund to provide redress for the class of patient claimants we have assembled. In exchange, all legal actions would be withdrawn. This strategy transforms COCOO from a simple claimant or campaigner into the neutral architect of a landmark settlement, resolving one of the most complex public policy failures in recent history.