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#Post#: 89744--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: RBDO
Date: September 13, 2025, 5:11 am
---------------------------------------------------------
If LoC refers to the original letter of claim (pardon my
ignorance) then the evidence provided was timestamped ANPR pics
of the car entering and leaving the car park.
I’m sorry if that isn’t what is being asked!
#Post#: 89747--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: RBDO
Date: September 13, 2025, 5:29 am
---------------------------------------------------------
Crumbs, sorry - I was typing and posting that last reply while
yours was coming through.
The section ‘Parking Charge Information’ states:
‘The signage which is clearly displayed at the entrance to and
throughout the car park, stated that this is private land and
that the car park is managed by Parkingeye Ltd. In addition the
signage states that, as a paid parking car park, a Parking
Charge is applicable if the motorist fails to make the
appropriate tariff payment. The signage also contains further
terms and conditions associated with this car park by which
those who park in the car park agree to be bound.
By either not purchasing the appropriate parking time or by
remaining at the car park for longer than permitted, in
accordance with the terms and conditions set out in the signage,
the Parking Charge is now payable to Parkingeye Ltd (as the
creditor).’
That’s as far as supporting evidence goes.
#Post#: 89748--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: b789
Date: September 13, 2025, 5:35 am
---------------------------------------------------------
No. You received a Parking Charge Notice (PCN) which was issued
as a Notice to Keeper (NtK). Because your appeal was not upheld,
they say you owe them a debt. Before they can issue a claim for
that alleged debt in the county court, they are required, under
the Pre Action Protocols for Debt Claims (PAPDC) to issue a
Letter of Claim (LoC) which details the reason they are alleging
you owe them a debt and they must give you 30 days to respond
before they can issue the actual claim.
You have shown us only the cover letter part of the LoC. What
else have they said about the alleged debt and why it is owed?
We don't need to know about any other forms that were included
with the LoC and you can safely discard those forms.
So, the LoC refers to the PCN, not any other LoC.
You can respond to the LoC with the following:
--- Quote ---
> 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.
>
> [indent]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.[/indent]
>
> 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]
--- End Quote ---
#Post#: 89766--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: RBDO
Date: September 13, 2025, 7:04 am
---------------------------------------------------------
That is wonderful, thank you so much. I apologise for my
ignorance.
Very grateful for your advice.
I will get that done ASAP.
#Post#: 92154--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: RBDO
Date: September 30, 2025, 6:57 am
---------------------------------------------------------
So I received a reply today which I will post below. They didn’t
answer or provide a number of the requests, should I request
them again or just note to them that they have failed to
provide?
And I don’t know if they are being intentionally obtuse at the
end.
Many thanks guys.
Parkingeye reply:
We write further to your recent correspondence which concerned
the above referenced Parking Charge. We recently sent you a
Letter Before Claim which informed you that this Parking Charge
remains outstanding and had now been processed for further
action.
On the 25/05/2025 at 15:49 the vehicle with registration PF68LNN
was captured by Parkingeye’s Automatic Number Plate Recognition
(ANPR) cameras entering the car park at Challaborough Bay Pay &
Display Kingsbridge. The vehicle was subsequently captured
exiting the car park at 16:06.
The vehicle remained onsite for 16 minutes and the required
parking tariff was not purchased. Therefore, there was a breach
of the terms and conditions and a Parking Charge was issued in
accordance with the signage.
We note from your reply to our Letter Before Claim that you
dispute the outstanding sum. We can confirm that we have now
reviewed your correspondence but it is our position that the
Parking Charge remains due.
We can confirm that £130 remains outstanding and that full
payment is required within the next 14 days to prevent further
action.
Please find a breakdown of costs below:
Parking Charge full amount - £100
LBCC administration fee - £30
We are prepared to take legal action if necessary and should
court proceedings be issued, further costs will be incurred.
These will include, but are not limited to, the court claim
issue fee and the solicitors costs referred to within the Letter
Before Claim.
Please find a copy of the Parking Charge Notice attached, as
requested.
#Post#: 92186--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: b789
Date: September 30, 2025, 8:50 am
---------------------------------------------------------
Respond with:
--- Quote ---
> Your ref: [PCN/Ref]
> Site: Challaborough Bay Pay & Display, Kingsbridge
> Date of your Letter Before Claim: 29 August 2025
> By email: enforcement@parkingeye.co.uk
>
> Subject: Your response to my LBC reply – continuing dispute,
defective figures and missing documents
>
> Dear ParkingEye Enforcement Team,
>
> Liability remains denied.
> Your latest letter does not cure the defects I identified. You
have still failed to provide (i) contemporaneous photographs of
the actual signage at the location on the material date, (ii)
the exact clause(s) you say were breached, and (iii) the
landowner contract proving your standing to issue charges and to
litigate in your own name. Those documents were expressly
requested and are required if you intend to rely on them.
Provide them within 30 days. I will not use a web portal.
>
> Your ANPR timings are misconceived. You say ANPR captured
entry at 15:49 and exit at 16:06. That is 17 minutes between
cameras, not 16. In any event, ANPR timestamps do not equate to
a “period of parking”. They include circulation time, the time
required to read and consider terms, and lawful
consideration/grace periods mandated by industry codes. If you
dispute this, point me to your pleaded legal basis and to the
precise wording on the signs you say formed the contract that a
court will be asked to enforce. If you contend a breach,
identify the exact term and the factual conduct you say breached
it.
> You still refuse to identify the legal character of the £100.
Confirm whether you claim £100 as consideration under a
contractual term or as damages for breach. You must choose a
cause of action.
>
> Your £30 “LBCC administration fee” is not recoverable. It is a
pre-issue overhead that is already priced into the parking
charge. It is a classic example of double recovery and is
irrecoverable on the small claims track where only fixed costs
apply. If you believe otherwise, identify the statute or rule
that entitles you to recover a separate £30 administration sum
pre-issue and explain how that sits with CPR 27.14 and the
established prohibition on adding “debt recovery” or
administrative uplifts to a ParkingEye charge approved as a
single, inclusive sum. State whether VAT is chargeable on your
£30 and, if not, why not.
>
> You say a copy of the NtK is attached. If you intend to rely
on PoFA Schedule 4, identify where the NtK states a “period of
parking” rather than mere ANPR in/out times, and confirm the
dates and method of service relied upon for the statutory
presumption of delivery.
>
> For the avoidance of doubt, the claim is disputed on fact and
law. If you issue proceedings without first supplying the
missing documents and without correcting your incoherent and
inflated figures, 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).
>
> I expect the three missing items (signage photographs as
actually displayed on the material date, the verbatim clause(s)
you say were breached, and full landowner authority) together
with clear answers to the points above within 30 days. I will
then respond further. I will not engage with third-party debt
collectors.
>
> Yours faithfully,
>
> [Name]
> [Postal address]
> [Email]
--- End Quote ---
#Post#: 92208--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: RBDO
Date: September 30, 2025, 11:22 am
---------------------------------------------------------
Smashing, thank you!
I’ll get that gone tomorrow. Your continued help is very much
appreciated!
#Post#: 95281--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: RBDO
Date: October 23, 2025, 7:57 am
---------------------------------------------------------
So I received the following reply this week:
‘Reference: Parking Charge Notice -
Dear Sir / Madam,
We write regarding the above referenced Parking Charge, which
concerned a breach of
the parking terms and conditions on the 25 May 2025 at
Challaborough Bay Pay &
Display Kingsbridge, and your recent correspondence received in
relation to the same.
We can confirm that we have now reviewed your recent
correspondence, but we maintain
our position that the full amount of the Parking Charge remains
outstanding and that we
have been unable to reach an agreement in respect of the same
via the Reply Form.
We now require full payment of the outstanding sum of £130.00
within the next 14 days or
legal action will be taken. Should court proceedings be issued,
further costs will be
incurred. These will include, but are not limited to, the court
claim issue fee and the
solicitors costs referred to within the LBCCC.
Yours faithfully,
Parkingeye Team
If you wish to make payment, you can do so by telephoning our
offices on 0330 555
4444, by visiting www.parkingeye.co.uk, or by posting a
cheque/postal order to the
below address. Please note that you must quote the above Parking
Charge reference on
the reverse of the cheque or postal order.
Further Information
Whilst we appreciate that receiving a parking charge may be
inconvenient, we wish to
confirm that we will not be making payment of the sum referred
to within your
correspondence.
You have not formed a legally binding contract with Parkingeye
under which you have
acquired any right to invoice Parkingeye or seek payment for
goods or services, and the
sum sought is therefore rejected.’
I’m a little baffled about their reference to a sum I am
claiming, and can only presume they didn’t read the last reply
properly, and are references potential damages referred to.
They haven’t bothered to provide or excuse providing any of the
evidence I asked for which they will rely on, and this is the
second time I’ve requested, and given 30 days.
I don’t know whether to quote the specific legislation to them
re the first point, or just ask them what they are talking
about.
Re the continued absence of the provision of their authority
etc; do I request them again, and give them even more time, or
do I use this as evidence of their lack of cooperation/
disingenuity in this matter?
It seems as though whoever replied either doesn’t understand
what’s being asked, didn’t read it properly, or is being
intentionally obtuse/ disdainful.
Any advice — as always - is gratefully appreciated.
#Post#: 95339--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: b789
Date: October 23, 2025, 2:21 pm
---------------------------------------------------------
Their “we will not be making payment of the sum referred to
within your correspondence” is nonsense. You didn’t invoice them
for anything. Typical boilerplate paragraph dropped into the
wrong template.
Send one final, short chaser that (a) corrects their “sum you
claim” error, (b) records that they’ve twice ignored core
PAPDC-relevant document requests, and (c) gives a final,
reasonable window (14 days) to produce the three key items
(signage as displayed on the day, the exact clause allegedly
breached, and landowner authority). Make clear you won’t grant
further extensions and will seek CPR 27.14(2)(g) costs for
unreasonable conduct if they issue without providing them.
Do not keep rolling 30-day extensions. One clear ultimatum is
enough. If they still don’t comply and then issue, you use their
non-cooperation to support costs and case management orders.
Email the following response and CC yourself:
--- Quote ---
> 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:
> [indent]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.[/indent]
>
> 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]
--- End Quote ---
#Post#: 95383--------------------------------------------------
Re: ParkingEye PCN - Challaborough Bay P&D - No purchase of
appropriate time
DIR By: RBDO
Date: October 24, 2025, 4:20 am
---------------------------------------------------------
Brilliant as always, thank you.
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