I don't think it's based on the CP1 , but that's my opinion . The CP1 is a mighty fine pistol , in fact possibly the most accurate CO2 pistol that I've shot . The Nemesis is something different , more like a 2240/CP1 / HW40 combination . Obviously not SSP but in shape it's similar to the HW40 whilst the action reminds me of the 2240/CP1 .