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ECP appealhttps://ibb.co/FbLYcrss and https://ibb.co/VWBvcVsQPOPLA APPEALSorry for the formatting gore, this is the best I have as a transcript.Ground for appealThe vehicle was not improperly parkedAppeal claricationYou were still within the time you paid forWhat time did you park?24/11/2024 11:30What time did you leave the car park?24/11/2024 14:00How long did you pay for in the car park?3 hoursCan you upload any evidence to support that you were still within the time you paid for?Appeal claricationYour car parking ticket was clearly displayedWhere within your car did you display your parking ticket?on the dashboardCan you upload any evidence to support that your parking ticket was in clear view?-Appeal claricationThe terms and conditions of the car park were not properly signedWhy do you perceive that the terms and conditions of the car park were not properly signed (for example wherethey blocked, too small, or not showing)?Eurocarparks claim I have made a "major keying error" but on the sign at the entrace to the carpark there is no discussion ofa major keying error. Not one of those three words appears on the sign even individually (see attached photo). Eurocarparksseem to be construing a request on their sign "please enter full vehicle registration" as a term and condition There arevarious pieces of information on the sign at the entrance. Some are in a small font, and some are in a large font. The blockI've highlighted in blue appears to be the terms and conditions that motorists are expected to absorb and comply with. Thisis suggested by the design - a bold font, plenty of space around the writing to make it easy to read, and icons to structure it.The block i've highlighted in red in the uploaded image is written in a small font. Some of it is phrased as a request ("pleaseAppeal details Editextract of ECP spreadsheet containing mypaymentMotorist Ocial Documententer..."), while some of it refers to another part of the information as details rather than T&Cs ("see separate sign fordetails"). Most likely these are not intended to be absorbed by motorists due to the conversational request-like wording("please enter") and the design of the sign deemphasising this block. Many or most motorists will therefore interpret theTerms and Conditions as these three key points from the bottom block highlighted in blue: 1) purchase and retain a validticket or pay by phone 2) only park in a disabled bay if you hold a bdage 3) motorcyclists must pay the same tari as othervehiclesCan you provide any evidence to support your claim that the terms and conditions were not properly signed?Appeal claricationYou complied with the signage at the car parkWhat did the signage at the car park say?1) purchase and retain a valid ticket or pay by phone 2) only park in a disabled bay if you hold a bdage 3) motorcyclists mustpay the same tari as other vehiclesWhy do you consider you complied with the signage?I paid for parking for 3 hours, entered full vehicle registration (not partial), displayed my ticket on the car dashboard, andstayed less than 3 hours.Why does the parking operator consider you to have failed to comply with the signage?Eurocarparks claim that I have made a "major keying error" although there is no mention of major keying errors in the termsand conditions sign at the entrance. The parking operator claims that "Please enter full vehicle registration via the key pad" isa term/condition despite being written as a request and written in a small font and deemphasised in the graphic design ofthe sign (see previous box). Even if this small font request IS a term and condition that I am deemed to have agreed to, theparking operator claims that I have entered an incorrect registration, but have not provided evidence that I mistyped (such asCCTV footage of me entering the wrong number), and have not provided evidence that their machinery is in good order,there are no software bugs either within the machine, or within the onward data transmission process, and no administrativeerrors. Why would the driver enter a registration mark other than that of the vehicle? It doesn't make much sense. Even ifthis small font request IS a term and condition AND there was no machine or process fault within ECP Systems and I made anerror as I entered the full vehicle reg myself, I did not enter a partial registration, but I entered the full vehicle reg so was incompliance with their request to "please enter full vehicle registration". Even if I made a "major keying error", there is nothingin the terms and conditions that states that vehicle registrations with mistakes incur a penalty charge, and there is nomention of "major keying error" on the sign. Even if the small font request is a T&C, AND I made an error entering theregistration, this is not a major keying error, as the registration ECP claim I entered is substantially the same as theregistration of the vehicle (SK10HHP vs SK10OWZ). The majority of the letters and numbers ECP claim I entered are identicalto those on the vehicle, in particular the rst sequence of letters are identical, the subsequent sequence of numbers areidentical, and only the last letters are claimed to be dierent. So this is not a major keying error, and certainly nothing thatcould have prevented ECP's internal processes matching the payment to the vehcile (this car entered at this time, there was apayment associated with this similar reg a few minutes after entry). This is a far easier computational task than the one theyalready carried out to extract a car registation plate from a million pixels of various colours. I note that Eurocarparks haveretained the payment I made, rather than refunding it as soon as they decided it didn't correspond to any car that enteredthe car park...Can you provide any evidence to support your claim that you complied with the signage at the car park-Annotated picture of the sign at entrance fromECPMotorist PhotoPlease use this to provide an overall summary of the reasons for appealing against the parking charge notice.ECP have acknowledged that I paid the correct tari, have acknowleged that I departed before the time was elapsed, butclaim I have not complied with their terms and conditions, on faulty grounds.

I've acknowledged that I'm the registered keeper of the vehicle in both appeals. I've acknowledged paying for the ticket in the POPLA appeal. I have not stated that I was the driver.

28th Feb I received an NS1DT Claim Form: https://ibb.co/v4MZjd4SI would appreciate help with my response/defence.Timeline* Ticket purchased at machine, car left area within purchased time. ECP claim error entering registration into machine.* Sign at entrance merely requests full reg is entered https://ibb.co/Qvc7FWHm* Notice To Keeper Received https://ibb.co/TB8fx3Xq and https://ibb.co/HDyZQNrD* Appealed to ECP - Rejected https://ibb.co/FbLYcrss and https://ibb.co/VWBvcVsQ* Appealed to POPLA - Rejected* Letter of Claim received. https://ibb.co/zTSCcrkM* Replied via DCB Legal website asking for certain documents. No response received.* NS1DT claim received https://ibb.co/v4MZjd4SNot complied with pre-action protocolIt seems like DCB Legal may not have complied with PRE-ACTION PROTOCOL FOR DEBT CLAIMS in two ways. Firstly by not enclosing information sheet/reply form. Secondly by opening a claim without waiting 30 days from the reply and without providing me the documents I asked for.3.1c "enclose a copy of the Information Sheet and the Reply Form atAnnex 1 to this Protocol"There was not an Information Sheet nor a Reply form enclosed with the letter. Although they offer at the bottom of the letter (https://ibb.co/zTSCcrkM) to send a physical copy if I phone then. Does this count at enclosing a copy?4.2 "the creditor should not start court proceedings less than 30 days fromreceipt of the completed Reply Form or 30 days from the creditor providingany documents requested by the debtor, whichever is the later."The Letter of Claim was dated 22 Jan 2026. I replied 30 days after the date of the letter on 21st Jan 2026. I replied via a form on DCB Legal's website which they claim was a reply form, althouh the form differed in some respects from the form in Annex 1 of the PRE-ACTION PROTOCOL FOR DEBT CLAIMS. In my reply I noted that they had not sent a reply for or information sheet. I indicated that I needed certain information (maintenance records/known issue list/certification the payment machine is fit for purpose and free of detects,the Terms and COnditions that ECP claim were in force, and a breakdown of the claimed debt). I saved copies of the form that I submitted on my computer.I have not been sent any of the requested documents (in fact not had any response at all), and then received a Claim From on 28th Feb. This is less than 30 days after the reply.Outline of DefenceThis is how I'm thinking of defending:1. disagree driver entered invalid reg, error in machine.2. sign (https://ibb.co/Qvc7FWHm) says "please enter full reg". Why did they include "please" if it's a term and condition rather than an optional request? Not a term and condition2a. CRA 2015 - contract terms must be fair and transparent. Disproportionate financial sanction for a paid for service is unfair.2b. CRA 2015 69Contract terms that may have different meanings(1)If a term in a consumer contract, or a consumer notice, could have different meanings, the meaning that is most favourable to the consumer is to prevail.3. Driver left within purchased time - ECP suffered no loss of revenue, no overstay, no misuse of spaceTherefore charge is punitive not protective (Legitimate interest test form Beavis 2015 - complied in substance)4. DCB Legal have substantially not complied with preaction protocol so the case should be stayed or discontinuedThanks in advance for any thoughts or advice shared..