I received a PCN at 15:58, during which I was in the process of purchasing my session on RingGo which eventually went through at 16:04, which is 6 minutes after I got the PCN.
Is there an argument here to appeal based on de minimis?
CEO obs started at 15.54, so let's assume that you didn't see and ignore them, which places you there and parked prior to 15.54.
You bought parking rights at least 10 minutes after you parked and not in the vicinity of the car...is what their facts show. Forget de minimis
How would you intend to counter this?