Head: Annihilator
Torso: Shockwave v1
Legs and Waist: Big Boa
Arms: Unsure

Ever wonder what Cobra does in between their fights with the 'Joes? Well, I imagine that they spend some time fighting Zartan's attempts at being granted patents for vehicles and weaponry that Cobra owns the copyrights to (I know it's weird, but hey.). That being said, Cobra Commander had Tomax and Xamot educate a bunch of higher-ranking Vipers and turn them into copyright lawyers. They fight Cobra's battles in the courts, so Cobra Commander can concentrate on other endeavors.

Note: To be honest, this is one where the concept came after the custom figure was built. I asked my brother what a good name would be for this guy and he came up with the name, so I have to give him credit.