You ignore Trace and any other useless debt recovery company.
Here is a suggested response to the LoC:
Dear Sirs,
Your Ref. ############
Proposed Legal Proceedings
Claimant: xxxxxx xxxxxxxx Ltd
I refer to your your letter of claim.
I confirm that my address for service for the time being - assuming you don't delay any claim - is as follows, and any older address must be erased from your records:
[Correct address here]
The alleged debt is disputed and any court proceedings will be vigorously defended.
How am I expected to guess the basis of your clients allegations? If alleging breach of contract, please provide a breakdown of the alleged "loss" and state whether the intention of enforcement is for deterrence or revenue.
If alleging trespass, please enclose further evidence of the perpetrator, proof of the liquidated damages alleged and the calculation of this sum by the landholder.
If a "contractual fee" is part of the amount claimed, I require a VAT invoice by return and an explanation from your client how they can allow drivers to park "in breach" for a fee if they were originally contracted to "disallow and deter" - not allow and profit from - unauthorised parking.
I note that there is no breakdown of the alleged debt amount. Please provide a detailed breakdown of the different elements of the amount claimed in your Letter of Claim as required under the PAP. I expect to be able to differentiate between the initial charge amount and any added amounts such as, but not limited to, damages, debt recovery costs, contractual charges, etc. and the VAT element on any added charges.
I require specific answers to the following two questions and under the PAP I am entitled to detailed answers:
1. Does the £150 include what is often dressed up as a 'Debt Recovery' fee, and if so, is this net or inclusive of VAT? If the latter, would you kindly explain why I am being asked to pay the operator’s VAT?
2. With regard to the principal alleged PCN sum: Is this damages, or will it be pleaded as consideration for parking?
Yours faithfully