Because the PoC are always so poor, if the defendant has no other information, until after the claim is made, they have a genuine cause to plead the failure of the claimant to state the cause of action.
The modus operandi over on MSE is not to request an SAR until after a claim is filed.
Many of these claims are now being thrown out because of the failure to properly set out the key details in each case, including the specific contractual terms relied upon, details of the alleged breaches, and quantification of the claimed losses - in breach of Civil Procedure Rules 16.4, 16PD3 and 16PD7.