Free Traffic Legal Advice

Your ref: [PCN/Ref]
Site: Challaborough Bay Pay & Display, Kingsbridge
Date of your Letter Before Claim: 29 August 2025

By email and post: enforcement@parkingeye.co.uk

ParkingEye Ltd, PO Box 117, Blyth, NE24 9EJ

Subject: Response to your Letter Before County Court Claim – figures queried and documents required

Dear ParkingEye Enforcement Team,

I acknowledge receipt of your Letter Before County Court Claim. Liability is denied.

Your figures are incoherent. You say the principal sum is £100, assert that under the Private Parking Single Code of Practice you are “entitled to add up to £70 to cover the cost of recovering a debt”, then declare an “additional fee of £30… now due” and demand £130. Identify precisely what the £30 represents, the legal basis for it, and whether VAT is included. If you contend that any part of this is a “debt recovery” add-on, explain why such a bolt-on is not an impermissible attempt at double recovery given that ParkingEye’s business model and the approved charge already include the cost of running your scheme. Confirm also whether you intend to pursue any sum beyond the principal, the fixed court fee and the fixed, permitted legal representative’s costs on issue.

Further, you must state the legal character of the £100: do you claim it as consideration under a contractual term, or as damages for breach? Your letter is silent on this, yet it is fundamental to any cause of action.

Please now provide the following, in full, legible and unredacted, within 30 days. I will not use your web portal.

1. A complete copy of the original Notice to Keeper exactly as served (all pages and images), including the wording relied upon to invoke Schedule 4 of the Protection of Freedoms Act 2012 and proof of service/delivery dates.
2. A contemporaneous, date-stamped photograph of the actual terms signage at the location on the material date (not artwork or a stock image) showing the full wording, the parking charge amount, the entrance signs and the signs’ positions relative to the bay/route used.
3. The exact clause(s) of the terms you say were in force and that you allege were breached, set out verbatim and cross-referenced to the signage supplied, together with clarification of whether you plead breach of contract, trespass, or a contractual sum by performance.
4. The written agreement in force on the material date between the landowner (or party with title) and ParkingEye, showing the land description and boundaries, commencement/expiry, consideration, and the express authority (if any) to issue PCNs, to pursue proceedings in your own name, and to recover the sums now claimed.
5. A full breakdown of all sums now claimed, identifying the legal basis for each head of loss or sum, whether the principal is consideration or damages, and whether any alleged “debt recovery” element attracts VAT. If you rely on any trade association code for add-ons, identify the specific provision and explain how it creates a recoverable legal entitlement.

If you commence proceedings without first addressing the above and rectifying the inconsistencies in your figures, I will draw this letter to the court’s attention and seek sanctions for unreasonable conduct, including costs pursuant to CPR 27.14(2)(g).

All future correspondence should be sent by post to my address and/or by email to [your email]. I will not engage with third-party debt collection agents.

Yours faithfully,

[Name]

Your ref: [PCN/Ref]
Site: Challaborough Bay Pay & Display, Kingsbridge
Date of your latest letter: [insert date]
By email: enforcement@parkingeye.co.uk

Subject: Your latest LBC correspondence – non-response to document requests and incorrect “sum claimed” assertion
Dear ParkingEye,

Your letter states you “will not be making payment of the sum referred to within [my] correspondence.” I have made no demand for payment of any sum from ParkingEye. Please correct your records and stop repeating this irrelevant template paragraph.

You have now twice failed to provide the core documents I requested that you will rely upon. For the final time before proceedings, provide within 14 days:

a) Contemporaneous, date-stamped photographs of the actual entrance and terms signage as displayed on the material date, at driver eye height and showing location relative to the bay/route used (not artwork/stock images).
b) The exact clause(s) you say were in force and allegedly breached, set out verbatim and cross-referenced to the signage supplied. Also confirm your pleaded legal basis (contractual sum by performance vs breach/trespass).
c) The landowner authority in force on the material date, unredacted as to parties, land description/boundaries, dates, consideration, and with express authority (if any) for ParkingEye to issue PCNs, to litigate in your own name, and to recover the sums now claimed.

You continue to demand £130 comprised of a £100 “Parking Charge” and a £30 “LBCC administration fee”. Identify the legal basis on which you contend a separate £30 pre-issue administration sum is recoverable in addition to the approved parking charge, and confirm whether VAT is (a) chargeable or (b) excluded, and why. If you cannot identify a proper basis, confirm the claim is limited to the principal, the court issue fee and the fixed, permitted legal representative’s costs on issue.

If you issue proceedings without first providing the items at 2(a)–(c) and a coherent explanation of 3), I will draw this correspondence to the court’s attention and seek appropriate sanctions for unreasonable conduct, including costs under CPR 27.14(2)(g). No further extensions will be agreed. I will not use a web portal.

Yours faithfully,

[Name]
[Postal address]
[Email]