VS Publicidade LTDA (the top-ranked AN-094 shell) routes 218 of its 254 mayoral polls (86%) through Publi. QC Pesquisas & Editoração — and Publi. QC self-contracted all 230 of its 2020 mayoral polls in São Paulo without an intermediary. The Goiás IPOP/FacUnicamps cycle-over-cycle shift recurs at this scale in São Paulo with a different cover entity. Owners are different people (Sanazar brothers for VS, Flávio Henrique da Silva for Publi. QC), so the relationship is contractual exclusivity rather than common ownership.
Question
VS Publicidade LTDA was named in the §2 national-pattern paragraph added in AN-094 as the single largest residual-tier shell in 2024 (254 mayoral polls registered). The paragraph is currently grounded on top-25 enumeration alone. To make it a worked case alongside the Goiás FacUnicamps anecdote that §2 already has, we need three things: the firm itself (ownership, registered activity), the actual poll pattern (which pollster, which municipalities, which dates, which candidates), and whether the cycle-over-cycle shell-shift documented in Goiás also appears here.
Results
Firm
- Name: VS PUBLICIDADE LTDA.
- CNPJ: 96.499.132/0001-89.
- Headquarters: Osasco, São Paulo.
- Registered: 2003-06-18. Existed for 21 years before the 2024 cycle.
- Capital social: R$ 0 (declared zero).
- Partners (May-2025 RFB socio snapshot, 8-digit cnpj_base
96499132):- MARCELO VREJHI SANAZAR (partner since 2003-06-18, qualificação 49)
- MARCIO RODRIGO SANAZAR (partner since 2003-06-18, qualificação 49)
- Declared CNAEs: a long list including journalism-printing ("Impressão de jornais", "Edição de jornais diários"), publicity ("Consultoria em publicidade", "Outras atividades de publicidade"), cinematography, and event photography. The journalism CNAEs are declared but the firm has no findable news brand, no recurring journalism output, and no public website.
- Web presence: none findable. Multiple targeted Google + econodata + casadosdados searches return only CNPJ-registry records.
2024 poll footprint
- Polls registered as contratante: 254 mayoral polls.
- UF concentration: 253 of 254 in São Paulo state; 1 in Mato Grosso do Sul. Single-state footprint despite the cross-state reach the registry permits.
- Time window: 2024-06-02 to 2024-10-03 — the 4-month 2024 municipal-campaign window.
- Mean amount declared: R$ 2,161 per poll. Total declared spend across 254 polls: R$ 551,050. Per-poll cost is roughly 4–7× lower than market rate for a standard 220-respondent mayoral poll, the typical sample size in the VS portfolio.
- Pollster concentration: 218 of the 254 polls (86 %) were produced by a single pollster, Publi. QC Pesquisas & Editoração LTDA (CNPJ 37.658.984/0001-02). The remaining 36 polls split across 5 other small pollsters (Quality Pesquisas 15, Vitoria Comunicação 10, Instituto Nova S.P. 5, Amaral dos Santos 4, AR7 Pesquisas 2).
Publi. QC, the paired pollster
- CNPJ: 37.658.984/0001-02.
- Registered: 2020-07-08. Founded 4 years before 2024 cycle.
- Partner (sole): FLAVIO HENRIQUE DA SILVA (partner since 2020-07-08, qualificação 49). No relation to the Sanazar brothers.
- 2024 mayoral output: 219 polls in 2024 — 218 of them sponsored by VS Publicidade, 1 sponsored by MAC CLEAN SOLUÇÕES. One client, effectively.
- 2020 mayoral output: 230 polls — but in 2020 every single one was self-contracted by Publi. QC (sponsor row = "PUBLI. QC PESQUISAS & EDITORACAO LTDA" itself). No external contratante on any of the 230 registrations.
Cross-cycle inversion
The Goiás case in §2 documents IPOP-Cidades shifting from self-contracting in 2020 (357 polls, all named IPOP itself as contratante) to FacUnicamps shell-contracting in 2024 (68 polls, all named FacUnicamps). The same shift occurs in São Paulo with Publi. QC and VS Publicidade — at very similar scale:
| Pollster | 2020 mayoral polls | 2020 contratante | 2024 mayoral polls | 2024 contratante (218 of 219) |
|---|---|---|---|---|
| IPOP-Cidades (Goiás) | 357 | IPOP itself (self) | 68 | FacUnicamps (shell) |
| Publi. QC (São Paulo) | 230 | Publi. QC itself (self) | 219 | VS Publicidade (shell) |
The cover vehicle changes across cycles; the pollster's volume does not. Both 2020 self-contracting patterns are exactly the disclosure-failure type Lei~9.504/97 Art.~33,~§3° formalizes as fineable but not criminal (paper §2). Both 2024 shell shifts move the same volume of polls through a third-party CNPJ whose web presence, declared activity, and ownership structure all fail to match the editorial role the registration assigns it.
Candidate side (partial — IPOP-iceberg layer present)
- Of 254 VS-sponsored polls, 129 (51 %) have the LLM-extracted
vote-intention data in
poll_response_2024.parquet. The other 125 don't — same disclosure-iceberg layer the §2 paragraph documents for IPOP (where only 25 % of polls had any uploaded PDF). - Among the 129 with response data, no single candidate appears in more than 3 polls. Unlike a single-candidate vehicle pattern, VS Publicidade is best read as a multi-race aggregator shell: many different mayoral races, each with its own (unidentified) candidate funder routing through the same VS→Publi. QC pipeline. This matches the FacUnicamps pattern, where the shell sponsored polls in races across Goiás for unknown sets of candidate funders.
Interpretation
VS Publicidade ↔ Publi. QC is the São Paulo analogue of FacUnicamps ↔ IPOP-Cidades in Goiás. Same cycle-over-cycle shift (self → shell), same single-pollster pairing, comparable scale (~220 polls / cycle), same registry signature (low or zero capital social, declared CNAEs the firm doesn't actually practice, no public web brand).
The cross-cycle inversion is the load-bearing comparative fact. The paper's §2 closing line — "the cover vehicle changed across cycles; the pollster's volume did not" — is now exactly right for São Paulo, the country's largest electoral market.
Different owners. Unlike a single-family enterprise, the Sanazar brothers (VS) and Flávio Henrique da Silva (Publi. QC) are unrelated. The exclusivity is contractual, not familial. This matters for the legal-asymmetry argument in §2: a same-owner arrangement could be characterized as integrated journalism; an arms-length contractual exclusivity at this scale (219 of 219 polls go through one sponsor) is structurally indistinguishable from a sponsorship-laundering arrangement, but Art.~33,~§3° reaches only the disclosure failure, not the contractual relationship.
Follow-ups
Beneficiary identification (puzzle): which actual candidates' campaigns funded the 218 VS→Publi. QC polls? The 129 polls with response data show no single-candidate concentration — but per-poll, who was the favored candidate? A bias regression on the VS subsample alone (errror within race × week vs the subsample's leading candidate) could surface a candidate-level slant pattern even without funder identification. Suggested script:
source/analysis/an-095a-vs-bias-by-race.py.VS Publicidade's 1 MS poll (blind spot): 253 of 254 in SP, 1 in MS. Worth checking which muni + which race; it may be a coding artifact, may be a one-off, may indicate the shell was tested cross-state.
The 36 non-Publi.QC polls in VS's 2024 portfolio (puzzle): Quality Pesquisas (15), Vitoria Comunicação (10), Instituto Nova S.P. (5) — are these other small SP pollsters that VS Publicidade uses opportunistically, or do they show the same self→shell shift if you look at their 2020 cycle?
MAC CLEAN SOLUÇÕES (blind spot): the 1 non-VS poll that Publi. QC did in 2024 was sponsored by "MAC CLEAN SOLUÇÕES E APOIO ADMINISTRATIVO LTDA" — a cleaning-services LTDA. Is that another shell in the same network, or a one-off legitimate contract?
Were the Sanazar brothers ever candidates? (diagnostic): if either Marcelo or Marcio Sanazar appears in TSE candidato as a 2024 mayoral candidate, VS Publicidade is much closer to a Route A self-sponsored case than to a shell-cover one. Quick check against candidato.csv.Resolved 2026-06-17. Neither Marcelo Vrejhi Sanazar nor Marcio Rodrigo Sanazar appears as a candidate in any year. The only Sanazars in TSE candidato are Hirant Sanazar (Dep. Estadual 1998 PRONA / Dep. Federal 2002 PL, SP) and Sandra Regina Sanazar (Vereador 2008 PP, SP, 65 votes) — possible family connection to the VS partners, but neither is a 2024 mayoral candidate. The shell-not-Route-A characterization in §2 stands.
Caveats
- All evidence here is registry-side. The label "shell" is an inference from the absence of a public brand + the cross-cycle inversion + the contractual exclusivity. A definitive characterization would need bank records, contracts, or testimony — same evidence bar as Operação Leão de Neméia.
- The 51 % response-data coverage (129 of 254) means we observe candidate-favorability claims on only half VS Publicidade's registered output. The other 125 are like the 51 IPOP polls without uploaded relatórios in AN-083 — structurally invisible.