Author Lord Archer hosts ICC at House of Lords

  1. Best-selling author Jeffrey Archer, who sits in the House of Lords as Lord Archer of Weston-Super-Mare, faces serious questions about his judgement after hosting a reception in the House of Lords last September for property developer and investor Imperial Corporate Capital PLC (ICC).
  2. I have serious concerns about the opaque ICC, many of which I’ve documented on my blog. It’s made false and exaggerated claims on its website, for example. To date I’ve published eight posts, including this one, about the firm. My penultimate, ICC drops legal action against me”, appeared on 11 February 2020. (That post lists the previous six.) The revelations there are the most serious to date – revelations about ICC that arose during its protracted and time-consuming legal action against me.
  3. On 25 September 2019, ICC held a reception at the House of Lords, in the Cholmondeley Room and Terrace, according to the “Hospitality events at the House of Lords” page on the parliament website. Lord Archer was the sponsoring peer for the event.
  4. I brought my 11 February 2020 post about ICC to the novelist’s attention in an email, requesting comment on the firm and its credibility.
  5. Lord Archer replied: “I believe I met Mr King at the Asian Business Awards where I was conducting the charity auction. I did indeed attend the hospitality event at the House of Lords last September but have no business or personal association with Imperial Corporate Capital, and am sorry not to be able to give you any more help.”
  6. In response, I said: “In light of my findings, I believe your decision to host a reception for ICC at the House of Lords raises serious questions about your judgement.” Again, I invited comment. Lord Archer didn’t come back, though.
  7. ICC makes great play of its events at the “prestigious House of Lords” in its marketing on social media (screen shot in Figure 1) and always has done (see 21 March 2019 post). Thus the firm uses parliament to lend it credibility. This is a serious issue.

    Figure 1. Imperial Corporate Capital PLC tweets on 23 October 2019 about its recent event at the “prestigious House of Lords”

  8. ICC invites investors in the UK and overseas to trust it with their money. Yet ICC is an unauthorised firm! The FCA website warns consumers: “We strongly suggest you avoid dealing with unauthorised firms.”
  9. The “Mr King” to whom Lord Archer refers is Abbey King Khawaja, “director of government relations” at ICC (see 21 March 2019 post). There’s a photo of the peer with Mr Khawaja on the latter’s personal website (screen shot in Figure 2).

    Figure 2. Lord Archer (left) with Abbey King Khawaja: photo on the latter’s personal website at 25 February 2020

  10. On 24 April 2016, I exposed Mr Khawaja for being an official supporter of the Conservatives – but as a director of a fake company. What’s more, back then his fake company claimed on its website the backing of then Tory prime minister David Cameron! That laughable website disappeared long ago, but there are screen shots in the post. In the second post on the same day, I also revealed Mr Khawaja had somehow succeeded in getting his fake company selected by then government department UK Trade & Investment (UKTI) for its October 2014 market visit to South Africa. An astonishing due diligence failure by UKTI.
  11. It was my interest in Mr Khawaja and his activities that led me to ICC.
  12. On 2 July 2019, I revealed Mr Khawaja had vanished from the ICC website, following my posts about him and the firm. As you can see, back then Mr Khawaja promised legal action against me but I heard nothing.
  13. The ridiculous claims of Mr Khawaja and ICC belong in a Jeffrey Archer page-turner, not parliament. It beggars belief Lord Archer was happy to host them at the House of Lords.

“It’s all about who you know”: Jeremy Hunt’s accountant boasts of invitation to Foreign Office to meet then foreign secretary

  1. In autumn 2018, Jeremy Hunt‘s accountant, David Grunberg, boasted to his clients about his invitation to the Foreign Office to meet Mr Hunt, the then foreign secretary. Plugging his Brexit advice, Mr Grunberg revealed he’d discussed Brexit with his cabinet-minister client that day.
  2. Mr Grunberg is the founder of accountancy firm Grunberg & Co, where he was until recently the senior partner. He’s now a consultant at the firm, the website shows (screen shot in Figure 1).

    Figure 1. Grunberg & Co website: David Grunberg at 20 February 2020

  3. The founder sends clients of Grunberg & Co a monthly email newsletter, “Financial Therapy – Three Minute session with David Grunberg”.
  4. In October 2018, there Mr Grunberg reported back on his meeting at the Foreign Office with “long-time contact of our firm” Mr Hunt: We had some time to discuss Brexit and the ongoing uncertainty that the country is facing. It was clear that Jeremy understood the fears and concerns of many of our clients, and was able to share some useful thoughts about the progress of the talks, and proposed future arrangements for the UK.” (screen shot in Figure 2) The accountant went on to advertise his – not the foreign secretary‘sreadiness to discuss clients’ “preparations for Brexit”.

    Figure 2. David Grunberg’s “Financial Therapy” newsletter October 2018

  5. Meanwhile, Mr Grunberg couldn’t resist writing again the next month about his meeting with client Mr Hunt in Whitehall, which was only possible because the accountant had “pulled a few strings” (screen shot in Figure 3). He told his readers: “As they say, it’s all about who you know and thankfully as a long-term contact of our firm, Foreign Secretary Jeremy Hunt was more than happy to spend time with me.” Mr Grunberg finished with more bragging: “At Grunberg & Co we are constantly meeting with key decision-makers both here in the UK and overseas to ensure that our clients are prepared for whatever the future may bring.” What access to power!

    Figure 3. David Grunberg’s “Financial Therapy” newsletter November 2018

  6. Here Mr Hunt’s conduct undermines public trust and confidence in ministers and government.
  7. It’s surely inappropriate for the foreign secretary to meet his accountant at the Foreign Office to discuss, well, what exactly? They covered “a wide range of matters”, says Mr Grunberg (Figure 2) Suffice to say, the accountant handles Mr Hunt‘s private interests, not government business.
  8. Further, was Mr Grunberg lobbying the senior minister on behalf of another client(s)? The accountant’s boasts about his access to the foreign secretary and other “key decision-makers” risk creating the impression he (Mr Grunberg) acts as a political lobbyist.
  9. Equally, it’s surely inappropriate for Mr Grunberg to use his business relationship with the cabinet minister to promote Grunberg & Co. Why does Mr Hunt allow his accountant to use their business relationship this way?
  10. Now on the back benches, Mr Hunt has recently launched a new venture with Mr Grunberg. Both are trustees of fledgling charity Patient Safety Watch (screen shot in Figure 4). Mr Hunt became a trustee on 18 December 2019, according to the register of MPs’ financial interests. That both are trustees of the same charity is problematic given the two are linked and non-independent. There’s only one other trustee, too: patient safety campaigner James Titcombe.

    Figure 4. Charity Commission website: trustees of Patient Safety Watch at 20 February 2020

  11. What’s more, the chief executive of Patient Safety Watch is one of Mr Hunt’s former ministerial special advisers: Adam Smith. Cosy!
  12. Patient Safety Watch deserves scrutiny for another reason. It represents another corporate reporting failing by Mr Hunt.
  13. Patient Safety Watch is a charitable company, and as such is registered with Companies House, as well as the Charity Commission. Yet the charitable company has failed to report Mr Hunt is a director (trustee) (screen shot in Figure 5). Its a legal requirement for firms to keep their records at Companies House up to date.

    Figure 5. Companies House website: officers of Patient Safety Watch at 20 February 2020

  14. As I say, this isn’t the first time the former cabinet minister has messed up over Companies House filings. On 9 April 2018, I exclusively revealed that the then health secretary hadn’t filed correct “persons with significant control” information for who owned his and his wife’s firm, Mare Pond Properties Limited. Mr Hunt duly corrected the errors straightaway after my email – but didn’t respond to requests for comment. On 13 April 2018, the Daily Telegraph newspaper used my investigation as the basis of its front-page lead story, “Hunt admits breaking rules over luxury flats”. The rest of the national press followed up the story the next day.
  15. Mare Pond Properties Limited and Patient Safety Watch share the same north London registered office address – the head office of Grunberg & Co. The accountancy firm was also the company formation agent for Mare Pond Properties Limited, date of incorporation: 19 September 2017.
  16. Mr Hunt didn’t respond to an emailed request for comment before a reasonable deadline.

Telegraph reports my upheld complaint about the conduct of Lord Stevens of Kirkwhelpington

  1. On 19 February 2020, the Daily Telegraph newspaper reported my upheld complaint to the House of Lords Commissioner for Standards about the conduct of Lord Stevens of Kirkwhelpington (see previous post).
  2. Here’s a scanned copy of the Telegraph story in its print edition (“Lord Stevens apologises for work declaration omissions”): Telegraph 19 Feb 2020.

Chair and director Lord Stevens is also self-employed consultant to his own company

  1. Lord Stevens of Kirkwhelpington was commissioner of London’s Metropolitan Police from 2000 until 2005. Among other roles, he’s now chair and a director of Quest Global Limited, a company whose business is “investigations and integrity services”, according to the register of lords’ interests. The peer is also a self-employed consultant to his own company – an arrangement that warrants scrutiny.
  2. On 26 July 2019, The Guardian newspaper revealed in its print edition that Quest Global was involved in the dispute between the ruler of Dubai and his estranged Jordanian princess wife.
  3. That day I emailed Lord Stevens at Quest Global. Back then the latest accounts were made up to 31 December 2017. There note 13 in the notes to the financial statements (“related-party transactions”) says: “During this year the director, [sic] Lord Stevens also charged consultancy fees to the value of £104 186 (2016: £99 225).” There I asked the peer why he chose in 2017 to be paid £104 186 as a consultant to the firm, rather than as an employee of it.
  4. I didn’t receive a response to the email – nor to one a week later.
  5. On 3 October 2019, Quest Global published its 2018 accounts. These show the arrangement continues; note 12 states: “During the year a director charged the company for consultancy fees to the value of £109 799 (2017: £104 186).”
  6. On 18 December 2019, I again asked Lord Stevens at Quest Global for comment, in a third email, now also referring to the latest accounts. Still no response.
  7. Why does this arrangement warrant scrutiny? Tax and National Insurance.
  8. Directors are office holders, not necessarily employed by a company. Here the directors are employees, according to the 2018 accounts; note 2 (“employees”) says: “The average monthly number of persons (including directors) employed by the company during the year was 8 (2017: 8)”.
  9. The register of lords’ interests confirms Lord Stevens is paid as a director of Quest Global (screen shot in Figure 1): “category 1”, “Directorships”, is for remunerated directorships only, according to the registration form. (

    Figure 1. Lord Stevens of Kirkwhelpington: Register of Lords’ Interests at 18 December 2019

  10. Employees pay income tax and National Insurance contributions under PAYE (Pay As You Earn). Self-employed workers aren’t paid through PAYE, however.
  11. Quest Global avoids paying employer’s National Insurance for the services Lord Stevens provides as a self-employed consultant. In other words, it’s cheaper for the firm than paying him as an employee. Quest Global has a financial incentive to pay the peer as a self-employed consultant, therefore.
  12. Here there are two key issues. First, is there a genuine separation between Lord Stevens’ director role, paid as an employee, and his other duties? Second, if there’s a genuine separation, does the peer pass the HM Revenue and Customs (HMRC) tests for self-employed status? If not, he should be paid as an employee for all his duties.
  13. The Quest Global accounts don’t disclose the services Lord Stevens performs as a self-employed consultant – nor does the register of lords’ interests (Figure 1). On the latter the peer simply states “Stevens Consultancy” under “category 2” of registrable interest, “Remunerated employment, office, profession etc.” Nevertheless the registration form at “category 2” quotes para 53 of the “Guide to the Code of Conduct”: “Members who have paid posts as consultants or advisers should indicate the nature of the consultancy or advice given, for example ‘management consultant’, ‘legal adviser’ or ‘public affairs consultant’.” Thus it appears Lord Stevens is in breach of this requirement: he fails to state the nature of the consultancy.
  14. Another problem with Lord Stevens’ entry on the register of lords’ interests is he omits to disclose a relevant interest under “category 3”, “Person with significant control of a company (PSC)”. Companies House records show he’s a PSC of Quest Global Holdings Limited, the parent (“holding”) company of Quest Global. Yet the peer hasn’t registered the interest – or any other – under “category 3”.
  15. On 8 January 2020, I complained in writing to the House of Lords Commissioner for Standards, Lucy Scott-Moncrieff, about Lord Stevens’ two apparent breaches in relation to his disclosures on the register of lords’ interests. Two days later, Ms Scott-Moncrieff informed me by letter she’d investigate the complaint.
  16. On 17 February 2020, the Commissioner published her report. ( There Ms Scott-Moncrieff upheld my complaint in full; and Lord Stevens accepted in a letter to her on 22 January 2020 that he’d breached the Code of Conduct in both cases. The peer now discloses the work of Stevens Consultancy on the register of lords’ interests: “investigations, security and integrity consulting services”.
  17. Lord Stevens spoke at the 2016 Telegraph Business of Sport conference, the event website shows. There his speaker biography says: “In this role [chair of Quest Global], Lord Stevens led the inquiry for the Premier League into alleged irregular payments in football player transfers and an investigation into F1’s Crashgate.” (screen shot in Figure 2). That sentence casts doubt on the separation between the peer’s duties as a director and his other duties.

    Figure 2. 2016 Telegraph Business of Sport conference: event website at 7 January 2020

  18. As I say, Lord Stevens at Quest Global didn’t respond to emailed requests for comment on his employment status there.
  19. Here the peer’s non-responsiveness stands in contrast to something he said in his letter to Ms Scott-Moncrieff of 22 January 2020: “I am accordingly always conscientious of my duties under the Code [of Conduct] and sensitive to the general principles of conduct identified by the Committee on Standards in Public Life” (CSPL). The 7 principles of public life, published on the CSPL website, include “accountability”. Under that heading, CSPL says: “Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.” Lord Stevens, though, didn’t respond to emailed queries about his employment status at Quest Global.

Care after Combat promotes Nigel Farage and his Brexit Party

  1. On 30 January 2020, comedian Jim Davidson joined politician Nigel Farage at an event in central London to unveil a portrait of Mr Farage entitled “Mr Brexit”. Painter Dan Llywelyn Hall has donated his picture of the Brexit Party leader to military charity Care after Combat, whose founder and chief executive is Mr Davidson. The charity is auctioning the painting on its website to raise funds (screen shot in Figure 1). Care after Combat is currently tweeting about the event and auction (screen shot in Figure 2).

    Figure 1. Care after Combat website: auction of “Mr Brexit” portrait of Nigel Farage at 7 February 2020

  2. The following day, Brexit Day, the Daily Telegraph newspaper published an account by political sketch writer Michael Deacon of the unveiling of the painting. (Daily Telegraph 31 Jan 2020) Brexiteer Mr Davidson is a “close friend” of Mr Farage and gave a speech at the event.

    Figure 2. Care after Combat tweets about unveiling of “Mr Brexit” and auction on 31 January 2020

  3. Yet charities must be politically neutral.
  4. Worse, this isn’t the first time Care after Combat has engaged in party-political campaigning.
  5. On 20 October 2018, I revealed that the charity was tweeting profusely in support of the Conservatives. This and other of my findings prompted charity regulator the Charity Commission to open a regulatory compliance case into Care after Combat (see 12 December 2018 post).
  6. Despite the commission’s intervention, the charity resumed tweeting in support of the Tories during the last general election (see 27 November 2019 post). Private Eye magazine reported that exposé (see 14 December 2019 post).
  7. Care after Combat has been closely linked to the Conservatives from the beginning (see 20 October 2018 post). Mr Davidson is a longstanding public supporter of the party. He’s a well-known Brexiteer, too.
  8. The charity shows blatant and repeated disregard for both the requirement for political neutrality and the Charity Commission. Care after Combat has no credibility while it acts this way.
  9. When asked for comment, a Charity Commission spokesperson said in an email: “We will be assessing the matters you have brought to our attention, and looking into Care after Combat’s overall compliance with previous advice and guidance, notably on the importance of ensuring it follows the rules around campaigning and political activity. Charities should be distinct from other types of organisations in their attitude and behaviour, in their motivations and methods. That must include ensuring any involvement they have with political parties is balanced.”

ICC drops legal action against me

  1. On 10 December 2019, property developer and investor Imperial Corporate Capital PLC (ICC) dropped its legal action against me.
  2. Former deputy prime minister Sir Nick Clegg appeared and spoke at swanky ICC promotional events in 2017 and 2018 (see 21 March 2019 post). While on 12 April 2018, the firm held a reception at the House of Lords attended by, among others, Jack Straw, the former cabinet minister. Mr Straw gave a speech at the event, according to the company website. Baroness Doocey was the sponsoring peer for the reception. Meanwhile, ICC last year publicly claimed it was linked to a Premier League football club until I brought the alleged connection to the club’s attention (see 21 March 2019 post).
  3. To date I’ve published only six posts about ICC (all dates 2019): 21 March; 4 April; 2 July; 13 August; 17 September and 3 October. I haven’t written about the firm since 3 October last year because of the protracted and time-consuming legal proceedings.
  4. Here I present significant revelations about ICC that arose during the legal action. For the avoidance of doubt, what follows isn’t an exhaustive account of the legal action.
  5. The solicitor acting for ICC was Adrian Samuel of law firm SO Legal Limited.
  6. On 4 October 2019, I received the first email from Mr Samuel. There he attached a sealed order His Honour Judge Dight CBE had made on 3 October 2019 at Central London County Court. ICC, the Claimant, was applying for an injunction against me, the Defendant. Its application was accompanied by two Witness Statements from Bobby Singh, vice-chairman and founder of the firm.
  7. The Court Order stated that the application for an injunction was adjourned to 10:00 on 11 October 2019. I was “to file and serve any evidence in response to the application by 4pm on 9 October 2019”.
  8. On 9 October 2019, I wrote a letter to the County Court at Central London (“letter to the Court of 9 October 2019) that contained a statement of truth. I submitted a letter as evidence because I was unaware a Witness Statement was expected.
  9. Meanwhile, the day before, I received a letter from SO Legal Limited late that afternoon in an email. There Mr Samuel complained about a further two comments on the blog submitted by readers, both of whom I don’t know. I acknowledged receipt in an email on 10 October 2019, where I also gave an initial response. There I told Mr Samuel I’d immediately (on 8 October 2019) removed the two comments about which he complained.
  10. The solicitor’s letter of 8 October 2019 threatened to sue me separately for defamation, unless I paid Mr Singh damages and his legal costs. Oh, and Mr Samuel wanted a full response by 10:00 on 11 October 2019 – the time and date of our hearing at the Court.
  11. The day before the hearing, Mr Samuel that afternoon emailed a third Witness Statement from Mr Singh. There ICC’s vice-chairman and founder made an astonishing admission in response to my letter to the Court of 9 October 2019.
  12. Before revealing his admission, I must describe a key part of Mr Singh‘s first Witness Statement: where he referred to letters from “two of our regular and trusted investor partners”. Mr Singh provided these letters as an exhibit. The two alleged companies were JP Global Wealth Management Ltd (JPGWM) and Willow Wealth Management Limited. (The name JP Global Wealth Management is somewhat similar to JP Morgan, the world’s largest bank.) My letter to the Court of 9 October 2019 documented several reasons why both letters were unconvincing.
  13. My letter also pointed out JPGWM isn’t registered with regulator the Financial Conduct Authority (FCA), despite identifying itself as a “financial planner” on its Facebook page (screen shot in Figure 1). The FCA website warns consumers: “We strongly suggest you avoid dealing with unauthorised firms.”

    Figure 1. JP Global Wealth Management Ltd: Facebook page at 5 October 2019

  14. In the letter to the Court of 9 October 2019, I wrote: I first became aware of JPGWM on 4 October 2019. On that day, the firm website was merely a holding page, undated, proclaiming: Our website is under construction. New website coming soon, stay tuned. ( At date of my letter the holding page is still there, unchanged.” (screen shot in Figure 2) At date of this post, too, the same laughable holding page remains!

    Figure 2. JP Global Wealth Management Ltd: website at 5 October 2019

  15. As I said then, we can dismiss JPGWM and its alleged letter because the firm isn’t FCA-authorised. (On 16 October 2019, I reported JPGWM to the FCA as an unauthorised firm, making clear its link to ICC. The regulator subsequently requested more information.) Also, it’s unclear whether JPGWM is independent of Mr Singh or not, as I showed in the letter to the Court of 9 October 2019.
  16. However, Willow Wealth Management Limited is FCA-authorised. Thus I finished the letter to the Court of 9 October 2019: “On the equally unconvincing letter allegedly from Willow Wealth Management Limited, I shall write to sole director Paul John Adair to ask whether the document Mr Singh presents is genuine.”
  17. But I didn’t even have to write to Mr Adair!
  18. In his Witness Statement of 10 October 2019, Mr Singh admitted the alleged letter from Willow Wealth Management Limited was “not in fact sent to the Claimant company”! He added that Adhum Carter Wolde-Lule, chief strategy officer at ICC, had been responsible for contacting a similar-sounding firm, Willow Wealth Consultants Limited. Thus the letter should have been from them!
  19. Yet Willow Wealth Consultants Limited isn’t FCA-authorised, either! Thus like JPGWM, it isn’t a credible firm – and so can be dismissed as well.
  20. Mr Carter Wolde-Lule‘s Witness Statement of 10 October 2019 in relation to the alleged letter from Willow Wealth Management Limited would be laughable if it wasn’t so serious. There the ICC chief strategy officer referred to an exhibit showing his alleged email exchange with Liam McWhinney, sole director and owner of unauthorised firm Willow Wealth Consultants Limited. In his email, Mr Carter Wolde-Lule reveals he “put together” the letter falsely presented as from Mr Adair at FCA-authorised Willow Wealth Management Limited! While in his response, Mr McWhinney tellingly even misspells the name of his company, referring to Willow Wealth Consultant [sic] Limited. Like both alleged letters, the two emails in the exchange were just plain badly written and amateurish.
  21. ICC isn’t FCA-authorised, of course, as I noted in my first post about the property developer and investor on 21 March 2019.
  22. Mr Singh made another interesting disclosure in his Witness Statement of 10 October 2019: Mr Carter Wolde-Lule would be in Court the next day “to address any issues” about the “administrative error” behind the alleged letter from Willow Wealth Management Limited.
  23. It’s important to note I didn’t receive Mr Carter Wolde-Lule‘s Witness Statement of 10 October 2019 before the hearing the following day. I actually got it in an email on 22 October 2019 – and only because I‘d requested it in a letter to Mr Samuel the day before. (My letter of 21 October 2019 was a full response to the solicitor’s one dated 8 October 2019.)
  24. Now to the hearing. I was surprised Mr Singh wasn’t there. I told His Honour Judge Luba QC I opposed the injunction application. He duly informed me I must present evidence to him as a Witness Statement, after I referred to my letter to the Court of 9 October 2019. The judge also questioned the barrister for ICC, Tracy Bird, whether it was possible to harass a company, as opposed to an individual(s). Ms Bird initially argued it was; but then indicated an application would be made by Application Notice to add or substitute an individual Claimant(s). In other words, ICC would amend its claim. The hearing was vacated.
  25. On 18 October 2019, ICC added Mr Singh to its claim. The injunction hearing would take place on 13 December 2019 at 10:00. While the deadline for me to serve a Witness Statement on SO Legal Limited would be 16:00 on 22 November 2019.
  26. Meanwhile, a shadowy and opaque company sought to disrupt the then six posts on the blog about ICC. On 13 October 2019, I received an email from Automattic Inc., the US company behind, informing me it had disabled public access to my 4 April 2019 post about ICC. This was because a third party had alleged I’d copied the post from them without permission. The DMCA takedown notice was submitted by Pablo Lopez Sanchez of World Intelligence Ltd. On 16 October 2019, I submitted a DMCA counter notice, where I showed the DMCA takedown notice was wholly without merit. There I also pointed out World Intelligence Ltd is a shadowy and opaque company. Companies House records show it was incorporated on 4 December 2017 and has a sole director, Diego Sanchez Gimenez, whos also the owner. Mr Sanchez Gimenez is Spanish and a resident of Spain, according to the public company register. To date World Intelligence Ltd has filed one set of accounts, made up to 31 December 2018. These show no evidence the firm is active. Meanwhile, the registered office address is merely a “virtual office”. In October 2019, I confirmed this in person by visiting the registered office address, which is in Manchester.
  27. In my DMCA counter notice, I also called for transparency and accountability. I disclosed ICC had begun legal proceedings against me. Thus I challenged Mr Lopez Sanchez to reveal for whom his firm was acting, if anyone. I asked: “Has his firm been paid to submit the DMCA takedown notice? If so, by whom?”
  28. On 16 October 2019, Automattic Inc. acknowledged receipt of my DMCA counter notice. It said: “Your DMCA counter notice has been received, reviewed, and forwarded to the claimant. The claimant now has a period of 10 business days to initiate legal action directly against you for the alleged infringement. If no such action is initiated (the claimant has been advised that they must send us any and all relevant documentation regarding any such action), we will restore access to the material in question at the end of the 10 business day period.
  29. Two weeks later, on 30 October 2019, I received an email from Automattic Inc. The company said: “In response to your DMCA counter notice, we have now restored the material at issue.” Thus the second DMCA takedown notice failed, too. (For the failure of ICC’s first DMCA takedown notice, see 3 October 2019 post.)
  30. Meanwhile, at date of my Witness Statement (21 November 2019) I’d heard nothing from Mr Lopez Sanchez and World Intelligence Ltd.
  31. As I wrote in my Witness Statement: “This skulduggery requires explanation. It’s reasonable to ask whether ICC or someone acting on its behalf arranged for bad-faith actor World Intelligence Ltd to submit its baseless DMCA takedown notice. Only ICC would benefit if my 4 April 2019 post about the firm was publicly inaccessible.”
  32. On 15 November 2019, I received a long, rambling email from Eduardo Vicente of Eliminalia Group. There a third of the way through Mr Vicente said: “I speak in legal representation of Mr Bobby Singh…” He also disclosed his alleged “law firm” is based in Barcelona, Spain. Meanwhile, the Eliminalia website proclaims “We erase your past”. Yes, really. The same slogan appeared at the foot of Mr Vicente’s email, too.
  33. Mr Vicente didn’t say whether he’s a lawyer. Nor did he mention which country’s legal system allegedly applies. Further, the Eliminalia website says nothing about being an alleged “law firm”.
  34. Mr Vicente asked me to remove three posts about ICC.
  35. On 18 November 2019 (next business day), I acknowledged receipt of Mr Vicente’s email, telling him I’d respond on 25 November 2019.
  36. Eliminalia has an office in Manchester, according to its website. Nevertheless Companies House records show no registered company of that name. The address of the alleged Manchester office is 53 Fountain Street, Manchester M2 2AN (screen shot in Figure 3). By happy chance, that’s also the registered office address of World Intelligence Ltd, the bad-faith actor that submitted the second unfounded DMCA takedown notice. Remember, too, World Intelligence Ltd’s sole director and owner, Diego Sanchez Gimenez, is Spanish and a resident of Spain, according to Companies House records.

    Figure 3. Eliminalia: address of alleged Manchester office at 18 November 2019

  37. The Eliminalia website is opaque. It doesn’t name any staff, for example. However, searching the NewsBank database for Eliminalia produces press releases – not newspaper reports – quoting the chair and founder of the firm: Diego Sanchez! He also uses the name Didac Sanchez. Thus it appears the same person is behind both bad-faith actor World Intelligence Ltd and Eliminalia. Which isn’t too surprising given what else we know about the firm that proclaims “We erase your past”.
  38. Further evidence Diego Sanchez Gimenez of World Intelligence Ltd is the same person as Diego Sanchez/Didac Sanchez of Eliminalia is the fact they’re the same age. Diego Sanchez Gimenez’s date of birth is November 1992, Companies House records show. While a report on the Telegraph website dated 27 August 2015 (“Spaniard claims to have cracked D-Day carrier pigeon code”) concerns an extraordinary claim made by “22-year-old Spanish IT entrepreneur” Didac Sanchez. (For the avoidance of doubt, the report omits to mention Eliminalia.)
  39. Finally, Diego Sanchez Gimenez is named as holder of the European Union trade mark for the brand Eliminalia. The trade mark bears the text: “Eliminalia We erase your past” (registered trade mark number: EU016123523).
  40. On 18 November 2019, I again visited the address 53 Fountain Street, Manchester M2 2AN, where a Regus business centre is located. Eliminalia isn’t a client of the centre, according to both receptionists. While World Intelligence Ltd continues to have a “virtual office” there, the Regus pair confirmed.
  41. As I wrote in my Witness Statement: “As with so much related to ICC, alleged ‘law firm’ Eliminalia is demonstrably not credible. It, too, can be dismissed.”
  42. On 25 November 2019, as promised, I emailed Mr Vicente at Eliminalia. There I told him I must do due diligence on his firm. Eliminalia has an office in Manchester, according to the website. Nevertheless Companies House records show no registered company of that name. I added that the address of the alleged Manchester office is 53 Fountain Street, Manchester M2 2AN. I also said I’ve visited the address: it’s a Regus business centre. However, Eliminalia isn’t a client of the centre, according to both receptionists. I finished by asking whether he cared to explain. (For the avoidance of doubt, I said nothing about World Intelligence Ltd.)
  43. In his next-day reply, Mr Vicente disclosed the link between Eliminalia and World Intelligence Ltd, saying the former is a “commercial brand” of the latter.
  44. On 27 November 2019, I made three points about World Intelligence Ltd in an email to him. First, World Intelligence Ltd has only a “virtual office” at the Regus business centre in Manchester city centre! Second, to date World Intelligence Ltd has filed one set of accounts, made up to 31 December 2018. These show no evidence the firm is active. Third, World Intelligence Ltd submitted a DMCA takedown notice against my blog on 10 October 2019, which I received in an email three days later. On 16 October 2019, I submitted a DMCA counter notice, where I showed the DMCA takedown notice was wholly without merit. On 30 October 2019, Automattic Inc. informed me in an email that it had restored public access to the relevant post. In other words, the DMCA takedown notice failed. The content of its DMCA takedown notice shows World Intelligence Ltd is a bad-faith actor. Thus the firm isn’t credible.
  45. I next heard from Mr Vicente on 2 December 2019, when he requested my phone number, because he “would like to have a conversation on the phone to clarify this situation”. On 10 December 2019, I received another email asking for my phone number, when Mr Vicente now said he wanted to “resolve this misunderstanding. I hope we can reach a favorable [sic] agreement for both parties.”
  46. In my same-day reply, I wrote: “Here phone calls aren’t appropriate. Everything in writing (email), please.” I went on to ask Mr Vicente to respond to the points I’d made in my email dated 27 November 2019.
  47. On 12 December 2019, the day before the scheduled second hearing, he replied: “DMCA’s request against your article was interposed wrongly by our partner, which is not working any more with us, due to did not wanted to remove all content.” (Yes, that garbled sentence was his.) Mr Vicente went on: “On the other hand, we did not know that you and my client were in a judicial process. That is why we would like to be able to mediate in this situation and reach a win-win solution at this point. We think it would beneficial for both parties if you are willing to talk with us.”
  48. I didn’t reply.
  49. Meanwhile, what was happening with Mr Samuel and SO Legal Limited? On 29 November 2019, I received a letter from him that afternoon via email and by post the next day, a Saturday. There the solicitor wrote: “…it is necessary to maintain the current action and pursue further legal action against you. We will now proceed with claims in defamation (on behalf of both Claimants) and in relation to personal data and continuation of the harassment claims (on behalf of Mr Singh).” Having detailed the additional legal action, Mr Samuel then proposed a “short stay” – he suggested 35 days – in the current proceedings, which “which will obviate the need for preparation for and attendance on 13 December”. He wanted my agreement by “return of post”, adding: “From 2 December we shall begin preparations for the 13 December. Costs will be incurred…”
  50. I replied by letter as quickly as I could – on 2 December 2019. Having addressed the points in his latest letter, I then wrote: “I don’t think the proposed stay is necessary. You could have sent your latest letter any time during the legal action to date, not just now. Also, the legal action has already been delayed and prolonged due to your belated addition of Mr Singh as the Second Claimant after the first hearing at the Court on 11 October 2019.”
  51. On 6 December 2019, another Friday afternoon, I received two letters in an email from Mr Samuel. The one dated 5 December 2019 dismissed my letter of 2 December 2019 and promised another letter(s) relating to further proceedings. Meanwhile, the second letter, dated 6 December 2019, said ICC and Mr Singh wanted to resolve matters by agreement ahead of the hearing on 13 December 2019. The Claimants wouldn’t seek costs from me, if I agreed to provide the undertakings Mr Samuel specified in his letter. Oh, and he wanted confirmation of my agreement by midday (12:00) 9 December 2019!
  52. On 9 December 2019, I emailed the solicitor that Monday morning, as requested. I told him I didn’t agree to provide the proposed undertakings. They were unreasonable and disproportionate. The time Mr Samuel had given for a decision was simply far too short, I added.
  53. Meanwhile, the next day, the solicitor emailed yet another letter. There the Claimants withdrew their injunction application against me.
  54. (It was also on 10 December 2019 that I finally received by post the two letters Mr Samuel had sent in an email on 6 December 2019. The postmark indicated it had been sent on 9 December 2019.)
  55. Thus the contested hearing scheduled for 13 December 2019 didn’t take place. Here’s the Court Order of that date, where His Honour Judge Freeland QC ordered that the injunction application be withdrawn: Court Order.
  56. As I say, this isn’t an exhaustive account of the legal action. There’s much more to say about JPGWM, for instance. Nevertheless I must mention the matter of ICC’s location. Mr Singh said ICC is “London-based” in his Witness Statement of 1 October 2019. Both his Witness Statement and the firm homepage at that time showed the address: 3 Lombard Court, London, EC3V 9BJ. Yes, this address is in London’s financial district, the prestigious City of London. But neither Mr Singh’s Witness Statement nor the ICC homepage disclosed this is the registered office address. (A registered office address, which is required by company law, appears on the public record at Companies House.) However, the property developer and investor didn’t trade from that address: it was just a “virtual office”. ICC actually trades from a far less glamorous location outside London: Medway City Estate, an industrial estate in Rochester, Kent!
  57. The current sole occupier of the building at 3 Lombard Court, London, EC3V 9BJ is – and was at date of my Witness Statement – A Room in Town (Group) Ltd, which trades as A Room in Town. There the firm offers six rooms for hire to talking therapists.
  58. (On 20 November 2019, ICC changed its registered office address, according to Companies House records. The new registered office address is: 559A Kings Road, London, SW6 2EB. Again, the new address is presented on the ICC homepage, without stating it’s the registered office address (screen shot in Figure 4).)

    Figure 4. Imperial Corporate Capital PLC: homepage at 8 February 2020

  59. ICC also creates the impression it’s based in London through use of a 020 3 landline phone number. The firm website shows 020 3519 2803 – and did prior to the recent change in registered office address. True, 020 is the area code for London. Yet a 020 3 number doesn’t necessarily indicate an entity is located in the capital: there are “virtual” 020 3 numbers as well. Hidden call diversion means a caller to a “virtual” 020 3 number such as ICC’s is simply unaware their call has been forwarded to, well, anywhere. As you can see, “virtual” 020 3 numbers are a gift to scammers wanting to create the impression they’re London-based, when they’re not.
  60. ICC’s legal action was designed to intimidate and silence me. The property developer and investor also delayed the matter from coming to Court, dragging things out. In the end, though, ICC dropped its legal action against me, which is telling. Further, the revelations about ICC that arose during it only increase my concerns about the unauthorised firm.