E1 ink expiration and supply concerns

FINAL PRE-FILING DEMAND

Short-Dated and Expired E1 Ink, Printer Lockout, Unavailable Proprietary Ink, and Continuing Consequential Loss

[DATE]

VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED AND EMAIL
Fantasia Trading LLC / eufyMake Customer Support and Legal Department
[VERIFY AND INSERT CURRENT NOTICE ADDRESS]
Copy: [VERIFY AND INSERT ANY ADDITIONAL ADDRESS]

Re: eufyMake E1 [BACKER NUMBER, ORDER NUMBER, AND SUPPORT TICKET]

To eufyMake and the entity responsible for my purchase:

This is my final pre-filing demand. I demand immediate replacement or reimbursement for [NUMBER] E1 ink cartridges that are now unusable, restoration of access to the essential proprietary ink required to operate the E1, and an appropriate remedy for additional ink loss caused by short-dated fulfillment, electronic expiration lockout, delayed replacement, or continuing stock shortages.

I am prepared to pursue the remedies available in my jurisdiction if this matter is not fully resolved. I am allowing a final opportunity to cure because additional ink remains at risk and the total loss may still be developing. This cure period is not acceptance of coupons, a release, or an agreement to limit my claim to the current amount.

1. Documented problem

The Kickstarter campaign described E1 ink as having a “12 Months” shelf life. My [IDENTIFY PRODUCT AND QUANTITY] was delivered on [DELIVERY DATE] with only [DAYS OR MONTHS] remaining—approximately [PERCENT] of that period. [DESCRIBE ANY SEPARATE REPRESENTATION YOU RELIED ON AND ATTACH IT.]

The E1 [DESCRIBE EXACTLY WHAT YOUR MACHINE DOES: e.g., displays an expiration warning, rejects an expired cartridge, or stops operating]. I cannot [DESCRIBE THE PRINTING FUNCTION ACTUALLY PREVENTED] without [IDENTIFY REQUIRED CARTRIDGE OR COLOR]. The cartridges listed in Exhibit A are therefore [EXPIRED, REJECTED, STRANDED, OR OTHERWISE IMPAIRED—USE ONLY WHAT IS TRUE].

On [DATE], customer support stated [QUOTE OR ACCURATELY SUMMARIZE THE RESPONSE]. I [ACCEPT OR REJECT] that proposal because [FACTUAL REASON].

2. Continuing loss

eufyMake controls the practical source of the proprietary consumables needed to restore operation. As of [DATE], [CARTRIDGE] was [SOLD OUT OR OTHERWISE UNAVAILABLE], as shown in the enclosed evidence. I cannot reasonably obtain a substitute. During this downtime, other eufyMake ink in my possession continues to lose finite usable shelf life.

Additional cartridges delivered on [DATES] expire on [DATES]. Exhibit B identifies those items as presently at risk. Their ultimate loss is not included in the current monetary demand unless and until it can be calculated and supported.

3. Applicable-law notice

[CALIFORNIA USERS ONLY—VERIFY APPLICABILITY:] The unqualified product description may support an express-warranty claim under California Commercial Code section 2313. This letter provides notice of the claimed breach under section 2607. Sections 2714 and 2715 address certain direct, incidental, and consequential damages. Civil Code section 1654 concerns interpretation of uncertainty against the party who caused it.

[OPTIONAL CONSUMER-LAW PARAGRAPH—DO NOT USE WITHOUT CHECKING:] If this was primarily a personal, family, or household purchase and the California Consumers Legal Remedies Act applies, this letter is also intended to demand correction under Civil Code section 1782. That statute has specific content, delivery, address, and waiting-period requirements. I will comply with all applicable requirements before seeking CLRA damages.

4. Required cure

To resolve this matter without filing, please provide a substantive written response within [NUMBER] calendar days after receipt confirming:

• Reimbursement of $[AMOUNT] for the items in Exhibit A, plus documented applicable tax and reasonable replacement expenses; or replacement, at my election, with fresh cartridges carrying a commercially reasonable remaining shelf life on delivery.
• Valid shipment tracking and the expiration date of every replacement cartridge.
• The proposed remedy for additional ink whose usable life is lost or materially impaired during downtime caused by unavailable required ink or delayed replacement.

A coupon, another short-dated shipment, partial replacement, or a response that does not restore the affected functionality will not constitute full cure unless I expressly agree otherwise in writing.

5. Filing position and damages

If this matter is not fully cured, I intend to seek the remedies available to me, including damages that have matured and can be documented by the filing date and allowable court costs. The amount presently quantified is $[AMOUNT], exclusive of [IDENTIFY OTHER DOCUMENTED AMOUNTS] and any additional loss described in Exhibit B.

I will update my damages schedule before filing to include related losses that become reasonably ascertainable. Nothing in this letter releases a claim, accepts an accord and satisfaction, or fixes the final amount of any future complaint.

Preservation of evidence

Because litigation is reasonably anticipated, please preserve records and electronically stored information concerning my purchase, including order and shipment records; cartridge lot, manufacture, and expiration data; firmware and software rules governing cartridge expiration and printer lockout; inventory and restock records; replacement policies; and communications concerning [BACKER, ORDER, OR TICKET NUMBER].

Please direct a substantive written response to the contact information below.

Sincerely,

[NAME]
[ADDRESS]
[EMAIL]
[TELEPHONE]

Exhibit A — Current damages

For each affected cartridge list: ink/color; serial number; delivery date; expiration date; remaining shelf life at delivery; current status; amount remaining; and claimed value. Attach photographs and proof of price.

Exhibit B — Additional ink at risk

For each item list: ink/color; quantity; delivery date; expiration date; current status; and the factual reason downtime may cause additional loss. Do not assign speculative damages.

Enclosures

[LIST ONLY DOCUMENTS ACTUALLY ENCLOSED]