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VCS court letter
Mustard11
post Sun, 27 May 2018 - 17:49
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[attachment=55516:7AB30717...36429D8F.jpeg]Hi all, really hoping I can get some assurance here after a sleepless night.

Back in September 17 I received a pcn from vcs.

The vehicle had been parked in a private car park - which used to be NatWest bank but the building had recently been vacated so I and the other user of my car had parked there a few times before with no issues. The area is in a courtyard and several businesses have parking spaces there some of the spaces did have parking notices above them but above the spaces that were for NatWest there was no signage.

I do not have photos of signs and the space The vehicle was in as at the time the pcn was received. I can go and take some but there may be signs there now?

I just ignored the letters. I had been advised that these companies have no power to enforce. I have not been issued with any photographic evidence from vcs.

On Friday I received the enclosed letter. I am not sure if this is a genuine letter which has been forwarded to the court. Will I receive a letter from the court to confirm they have put a claim in against me?

I am hoping I may have a case to fight? From my I initial investigations does this qualify as a trespass issue?

My main concern is that I cannot get a CCJ, my occupation would not allow it so really do not want to go down the appeal route if I have no chance.

Any advice would be greatly appreciated



Picture of car park

This post has been edited by Mustard11: Sun, 27 May 2018 - 17:52
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Mustard11
post Fri, 1 Jun 2018 - 06:35
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Hi all

First draft of my defence here, please be gentle. I’ve spent hours going over other defences and trying to get something that fits. I have also sent a sar to vcs, under gdpr they should respond within one month.


I am xxxxxx, the defendant in this matter and the registered keeper of vehicle xxxxxx.

I deny I am liable for the entirety of the claim on the following grounds:

1. The Claim Form issued on the 25th May 2018 by Vehicle Control Services Ltd was not correctly filed under The Practice Direction as it was not signed by a legal person. The claim does not have a valid signature and is not a statement of truth. It states that it has been issued by Vehicle Control Services Ltd and signed by Simon Renshaw-Smith, who’s title is not stated. Practice Direction 22 requires that a statement of case on behalf of a company must be signed by a person holding a senior position and state the position. If the party is legally represented, the legal representative may sign the statement of truth but in his own name and not that of his firm or employer. The Particulars of Claim are however signed by Jake Burgess, Associate Legal Representative which further confuses the matter.

2. This Claimant has not complied with pre-court protocol (as outlined in the new Pre Action Protocol for Debt Claims, 1 October 2017) and as an example as to why this prevents a full defence being filed at this time, a parking charge can be for trespass, breach of contract or a contractual charge. All these are treated differently in law and require a different defence. The wording of any contract will naturally be a key element in this matter, and a copy of the alleged contract has never been provided to the Defendant.

a. There was no compliant Letter before County Court Claim, under the Practice Direction.

b. This is a speculative serial litigant, issuing a large number of draft particulars. The badly mail-merged documents contain very little information.

c. The Schedule of Information is sparse of detailed information.

d. The Claim Form Particulars were extremely sparse and divulged no cause of action nor sufficient detail. The Defendant has no idea what the claim is about why the charge arose, what the alleged contract was; nothing that could be considered a fair exchange of information. Furthermore, the Claim Form Particulars did not contain any evidence of contravention or photographs. These documents, and the Letter before County Court Claim should have been produced, pursuant to paragraph 6 of the Practice Direction Pre Action Conduct. This constitutes a deliberate attempt to thwart any efforts to defend the claim or to take stock, pursuant to paragraph 12 of the Practice Direction. Again, this totally contradicts the guidance outlined in the new Pre-Action Protocol for Debt Claims (2017), the aims of which are:

i. Early engagement and communication between the parties, including early exchange of sufficient information about the matter to help clarify whether there are any issues in dispute

ii. enable the parties to resolve the matter without the need to start court proceedings, including agreeing a reasonable repayment plan or considering using an Alternative Dispute Resolution (ADR) procedure

iii. encourage the parties to act in a reasonable and proportionate manner in all dealings with one another (for example, avoiding running up costs which do not bear a reasonable relationship to the sums in issue) and

iv. support the efficient management of proceedings that cannot be avoided.

e. The Defence therefore asks the Court to strike out the claim as disclosing no cause of action and having no reasonable prospect of success as currently drafted

3. The Claimant failed to meet the Notice to Keeper obligations of Schedule 4 of the Protection of Freedoms Act 2012 (POFA 2012). Such a notice was not served within 14 days of the parking event and when the notice was served, did not fully comply with statutory wording. The Claimant is therefore unable to hold the defendant liable under the strict keeper liability provisions:

The Claimant did not comply with POFA 2012 and give the registered keeper opportunity, at any point, to identify the driver. A Notice to Keeper can be served by ordinary post and the Protection of Freedoms Act requires that the Notice, to be valid, must be delivered no later than 14 days after the vehicle was parked. No notice to keeper was sent within the 14 days required to comply with POFA 2012 only a speculative invoice entitled Parking Charge Notice which was sent outside of the 14 day period, which did not comply with POFA 2012. This would exclude the registered keeper being liable for any charges.

Henry Greenslade, lead adjudicator of POPLA in 2015 and an eminent barrister and parking law expert, stated that However keeper information is obtained, there is no reasonable presumption in law that the registered keeper of a vehicle is the driver. Operators should never suggest anything of the sort. Schedule 4 also states that the only sum a keeper can be pursued for (if Schedule 4 is fully complied with, which it was not, and if there was a 'relevant obligation' and relevant contract' fairly and adequately communicated, which there was not) is the sum on the Notice to Keeper. They cannot pluck another sum from thin air and bolt that on as well when neither the signs, nor the NTK, nor the permit information mentioned a possible £160 for outstanding debt and damages. The additional costs, which the defendant contests have not been incurred, are none of its concern.

4. The Claimant has added unrecoverable sums to the original parking charge. I have not received any correspondence from a debt collection agency, so it is simply not credible that £60 debt collections charge were incurred. The Defendant believes that Vehicle Control Services Ltd has artificially inflated this claim. According to Ladak v DRC Locums UKEAT/0488/13/LA the claimant can only recover the direct and provable costs of the time spent on preparing the claim in a legal capacity, not any administration cost. The Defendant denies that the Claimant is entitled to any interest whatsoever.

5. This case can be distinguished from ParkingEye v Beavis [2015] UKSC 67 (the Beavis case) which was dependent upon an undenied contract, formed by unusually prominent signage forming a clear offer and which turned on unique facts regarding the location and the interests of the landowner. Strict compliance with the BPA Code of Practice (CoP) was paramount and Mr Beavis was the driver who saw the signs and entered into a contract to pay £85 after exceeding a licence to park free. As far as I can ascertain, based upon the very vague particulars of claim and complete lack of evidence and photographs, and without having been furnished with the alleged signage contract, none of this applies in this material case.

6. In the absence of any proof of adequate signage contractually bound the Defendant then there can have been no contract and the Claimant has no case

a. The Claimant is put to strict proof at the time of the alleged event they had both advertisement consent and the permission from the site owner to display the signs

b. In the absence of strict proof I submit that the Claimant was committing an offence by displaying their signs and therefore no contract could have been entered into between the driver and the Claimant

c. Inadequate signs incapable of binding the driver this distinguishes this case from the Beavis case:

i. Sporadic and illegible (charge not prominent nor large lettering) no site/entrance signage - breach of the POFA 2012 Schedule 4 and the BPA Code of Practice and no contract formed to pay any clearly stated sum
ii. It is believed the signage was not lit and any terms were not transparent or legible; this is an unfair contract, not agreed by the driver and contrary to the Consumer Rights Act 2015 in requiring a huge inflated sum as compensation from by an authorised party using the premises as intended
iii. No promise was made by the driver that could constitute consideration because there was no offer known nor accepted. No consideration flowed from the Claimant
iv. The signs are believed to have no mention of any debt collection additional charge, which cannot form part of any alleged contract.
v. The car park consists of 13 parking spaces, each space containing different signage, four spaces show “Snake Lane Design” , three have VCS parking notice above, these being in a separate area to where the Vehicle was parked. The remainder of the spaces are spaces reserved for Bank Staff, the bank has vacated the premises and no subsequent business has moved in. The Vehicle was parked in a space marked “Assistant Manager” there was no clear signage either upon entry to the car park, above the bay or adjacent to the bay noting any parking restrictions.

d. BPA CoP breaches this distinguishes this case from the Beavis case:
i. The signs were not compliant in terms of the font size, lighting or positioning
ii. The sum pursued exceeds £100
iii. There is/was no compliant landowner contract

7. No standing this distinguishes this case from the Beavis case:
It is believed Vehicle Control Services Ltd do not hold a legitimate contract at this car park. As an agent, the Claimant has no legal right to bring such a claim in their name which should be in the name of the landowner.

8. The Beavis case confirmed the fact that, if it is a matter of trespass (not breach of any contract), a parking firm has no standing as a non-landowner to pursue even nominal damages.

9. The charge is an unenforceable penalty based upon a lack of commercial justification. The car park is for a vacated building and has no impact on consumer use or the generation of income. The Beavis case confirmed that the penalty rule is certainly engaged in any case of a private parking charge and was only disengaged due to the unique circumstances of that case, which do not resemble this claim.


10. Due to the length of time, the Defendant has little to no recollection of the day in question. It would not be reasonable expect a registered keeper to be able to recall the potential driver(s) of the car 9 months later. The burden rests with the Claimant to identify the driver, who is the only party potentially liable in cases where a parking firm is unable to rely upon the POFA.

The Defendant denies any liability whatsoever to the Claimant in any matter and asks the Court to note that the Claimant has:

(a) Failed to disclose any cause of action in the incorrectly filed Claim Form issued on 25 May 2018.

(b) Sent a template, well-known to be generic cut and paste 'Particulars' of claim which ignores the fact that this Claimant cannot hold registered keepers liable in law, due to their own choice of non-POFA documentation.

The vague Particulars of Claim disclose no clear cause of action. The court is invited to strike out the claim of its own volition as having no merit and no reasonable prospects of success.


STATEMENT OF TRUTH

I confirm that the contents of this Defence are true to the best of my knowledge and recollection.

This post has been edited by Mustard11: Fri, 1 Jun 2018 - 06:54
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Mustard11
post Sat, 2 Jun 2018 - 05:36
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Any help with the above is greatly appreciated smile.gif
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nosferatu1001
post Sun, 3 Jun 2018 - 00:50
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I'm out all weekend - can anyone else look?
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ostell
post Sun, 3 Jun 2018 - 08:24
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3) "..... No opportunity to identify the driver...." . I would be tempted to leave this out as it tempts the question from the judege of "Who was driving?"

Henry Greenslad bit:- you haven't defined POPLA

4) The defendant is, under POFA, only liable for the amount on the original Notice.
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Mustard11
post Mon, 4 Jun 2018 - 12:49
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Thanks Ostell

Here’s the bit where I show my lack of knowledge......

3) leave out the entire part or re-word the Henry Greenslade bit to include the detention of POPLA?

4) Add your suggestion to this part or replace with?

Thanks in advance
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ostell
post Mon, 4 Jun 2018 - 13:08
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Put it as. when you metion POPLA use " Parking on Private Land Appeals (POPLA) " so that the judge knows for certain what you are talking about. Keep greenslade

4 add. Within POFA their is a statement that the keeper can only be liable for the amount of the inital charge, not the additional add ins that they use.

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Mustard11
post Thu, 7 Jun 2018 - 20:09
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Thanks so much Ostell

Will revise and repost.
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Mustard11
post Fri, 15 Jun 2018 - 17:49
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Hi all, thanks so much for all the help so far. I believe I have made the correct amendments, can someone cast their eye over this and then I can get it emailed next week.


I am xxxxxx, the defendant in this matter and the registered keeper of vehicle xxxxxx.

I deny I am liable for the entirety of the claim on the following grounds:

1. The Claim Form issued on the 25th May 2018 by Vehicle Control Services Ltd was not correctly filed under The Practice Direction as it was not signed by a legal person. The claim does not have a valid signature and is not a statement of truth. It states that it has been issued by Vehicle Control Services Ltd and signed by Simon Renshaw-Smith, who’s title is not stated. Practice Direction 22 requires that a statement of case on behalf of a company must be signed by a person holding a senior position and state the position. If the party is legally represented, the legal representative may sign the statement of truth but in his own name and not that of his firm or employer. The Particulars of Claim are however signed by Jake Burgess, Associate Legal Representative which further confuses the matter.

2. This Claimant has not complied with pre-court protocol (as outlined in the new Pre Action Protocol for Debt Claims, 1 October 2017) and as an example as to why this prevents a full defence being filed at this time, a parking charge can be for trespass, breach of contract or a contractual charge. All these are treated differently in law and require a different defence. The wording of any contract will naturally be a key element in this matter, and a copy of the alleged contract has never been provided to the Defendant.

a. There was no compliant Letter before County Court Claim, under the Practice Direction.

b. This is a speculative serial litigant, issuing a large number of draft particulars. The badly mail-merged documents contain very little information.

c. The Schedule of Information is sparse of detailed information.

d. The Claim Form Particulars were extremely sparse and divulged no cause of action nor sufficient detail. The Defendant has no idea what the claim is about why the charge arose, what the alleged contract was; nothing that could be considered a fair exchange of information. Furthermore, the Claim Form Particulars did not contain any evidence of contravention or photographs. These documents, and the Letter before County Court Claim should have been produced, pursuant to paragraph 6 of the Practice Direction Pre Action Conduct. This constitutes a deliberate attempt to thwart any efforts to defend the claim or to take stock, pursuant to paragraph 12 of the Practice Direction. Again, this totally contradicts the guidance outlined in the new Pre-Action Protocol for Debt Claims (2017), the aims of which are:

i. Early engagement and communication between the parties, including early exchange of sufficient information about the matter to help clarify whether there are any issues in dispute

ii. enable the parties to resolve the matter without the need to start court proceedings, including agreeing a reasonable repayment plan or considering using an Alternative Dispute Resolution (ADR) procedure

iii. encourage the parties to act in a reasonable and proportionate manner in all dealings with one another (for example, avoiding running up costs which do not bear a reasonable relationship to the sums in issue) and

iv. support the efficient management of proceedings that cannot be avoided.

e. The Defence therefore asks the Court to strike out the claim as disclosing no cause of action and having no reasonable prospect of success as currently drafted

3. The Claimant failed to meet the Notice to Keeper obligations of Schedule 4 of the Protection of Freedoms Act 2012 (POFA 2012). Such a notice was not served within 14 days of the parking event and when the notice was served, did not fully comply with statutory wording. The Claimant is therefore unable to hold the defendant liable under the strict keeper liability provisions:

The Claimant did not comply with Protection of Freedoms Act 2012 (POFA 2012) and give the registered keeper opportunity, at any point, to identify the driver. A Notice to Keeper can be served by ordinary post and the Protection of Freedoms Act requires that the Notice, to be valid, must be delivered no later than 14 days after the vehicle was parked. No notice to keeper was sent within the 14 days required to comply with POFA 2012 only a speculative invoice entitled Parking Charge Notice which was sent outside of the 14 day period, which did not comply with POFA 2012. This would exclude the registered keeper being liable for any charges.

Henry Greenslade, lead adjudicator of Parking on Private Land Appeals (POPLA) in 2015 and an eminent barrister and parking law expert, stated that However keeper information is obtained, there is no reasonable presumption in law that the registered keeper of a vehicle is the driver. Operators should never suggest anything of the sort. Schedule 4 also states that the only sum a keeper can be pursued for (if Schedule 4 is fully complied with, which it was not, and if there was a 'relevant obligation' and relevant contract' fairly and adequately communicated, which there was not) is the sum on the Notice to Keeper. They cannot pluck another sum from thin air and bolt that on as well when neither the signs, nor the NTK, nor the permit information mentioned a possible £160 for outstanding debt and damages. The additional costs, which the defendant contests have not been incurred, are none of its concern.

4. The Claimant has added unrecoverable sums to the original parking charge. I have not received any correspondence from a debt collection agency, so it is simply not credible that £60 debt collections charge were incurred. The Defendant believes that Vehicle Control Services Ltd has artificially inflated this claim. According to Ladak v DRC Locums UKEAT/0488/13/LA the claimant can only recover the direct and provable costs of the time spent on preparing the claim in a legal capacity, not any administration cost. The Defendant denies that the Claimant is entitled to any interest whatsoever. Within POFA the maximum sum recoverable is the amount noted in the notice to keeper, not any additional debt collection charges or interest.

5. This case can be distinguished from ParkingEye v Beavis [2015] UKSC 67 (the Beavis case) which was dependent upon an undenied contract, formed by unusually prominent signage forming a clear offer and which turned on unique facts regarding the location and the interests of the landowner. Strict compliance with the BPA Code of Practice (CoP) was paramount and Mr Beavis was the driver who saw the signs and entered into a contract to pay £85 after exceeding a licence to park free. As far as I can ascertain, based upon the very vague particulars of claim and complete lack of evidence and photographs, and without having been furnished with the alleged signage contract, none of this applies in this material case.

6. In the absence of any proof of adequate signage contractually bound the Defendant then there can have been no contract and the Claimant has no case

a. The Claimant is put to strict proof at the time of the alleged event they had both advertisement consent and the permission from the site owner to display the signs

b. In the absence of strict proof I submit that the Claimant was committing an offence by displaying their signs and therefore no contract could have been entered into between the driver and the Claimant

c. Inadequate signs incapable of binding the driver this distinguishes this case from the Beavis case:

i. Sporadic and illegible (charge not prominent nor large lettering) no site/entrance signage - breach of the POFA 2012 Schedule 4 and the BPA Code of Practice and no contract formed to pay any clearly stated sum
ii. It is believed the signage was not lit and any terms were not transparent or legible; this is an unfair contract, not agreed by the driver and contrary to the Consumer Rights Act 2015 in requiring a huge inflated sum as compensation from by an authorised party using the premises as intended
iii. No promise was made by the driver that could constitute consideration because there was no offer known nor accepted. No consideration flowed from the Claimant
iv. The signs are believed to have no mention of any debt collection additional charge, which cannot form part of any alleged contract.
v. The car park consists of 13 parking spaces, each space containing different signage, four spaces show “Snake Lane Design” , three have VCS parking notice above, these being in a separate area to where the Vehicle was parked. The remainder of the spaces are spaces reserved for Bank Staff, the bank has vacated the premises and no subsequent business has moved in. The Vehicle was parked in a space marked “Assistant Manager” there was no clear signage either upon entry to the car park, above the bay or adjacent to the bay noting any parking restrictions.

d. BPA CoP breaches this distinguishes this case from the Beavis case:
i. The signs were not compliant in terms of the font size, lighting or positioning
ii. The sum pursued exceeds £100
iii. There is/was no compliant landowner contract

7. No standing this distinguishes this case from the Beavis case:
It is believed Vehicle Control Services Ltd do not hold a legitimate contract at this car park. As an agent, the Claimant has no legal right to bring such a claim in their name which should be in the name of the landowner.

8. The Beavis case confirmed the fact that, if it is a matter of trespass (not breach of any contract), a parking firm has no standing as a non-landowner to pursue even nominal damages.

9. The charge is an unenforceable penalty based upon a lack of commercial justification. The car park is for a vacated building and has no impact on consumer use or the generation of income. The Beavis case confirmed that the penalty rule is certainly engaged in any case of a private parking charge and was only disengaged due to the unique circumstances of that case, which do not resemble this claim.


10. Due to the length of time, the Defendant has little to no recollection of the day in question. It would not be reasonable expect a registered keeper to be able to recall the potential driver(s) of the car 9 months later. The burden rests with the Claimant to identify the driver, who is the only party potentially liable in cases where a parking firm is unable to rely upon the POFA.

The Defendant denies any liability whatsoever to the Claimant in any matter and asks the Court to note that the Claimant has:

(a) Failed to disclose any cause of action in the incorrectly filed Claim Form issued on 25 May 2018.

(b) Sent a template, well-known to be generic cut and paste 'Particulars' of claim which ignores the fact that this Claimant cannot hold registered keepers liable in law, due to their own choice of non-POFA documentation.

The vague Particulars of Claim disclose no clear cause of action. The court is invited to strike out the claim of its own volition as having no merit and no reasonable prospects of success.


STATEMENT OF TRUTH

I confirm that the contents of this Defence are true to the best of my knowledge and recollection.
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Mustard11
post Sun, 17 Jun 2018 - 15:14
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Hi all

Can someone have a look at this for me so I can get it emailed off next week.

Many thanks

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Mustard11
post Mon, 18 Jun 2018 - 13:46
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Hi all

I have been scouring this site and others for some kind of flow chart which explains what happens after I email my defence. I have seen bits about witness statements and court packs but am not sure what I need to get together? Any help is greatly appreciated as is any thoughts on the above appeal. I have until the end of the month to get it sent but am starting to panic a bit now as it’s getting close.
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ostell
post Mon, 18 Jun 2018 - 13:57
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There is one on MSE.

Your defence goes in, VCS may or may not reply to it. You then get a Directions questionnaire from the court where you select mediation if you want it and your local court. You send the completed form to the court and VCS's solicitor. You should also receive a copy of the other sides direction questionnaire. All may go quiet for a while but then you will get a date for the hearing (could be some time ahead) and the instructions to submit a witness statement a short while before the hearing, normally 14 days but not necessarily. You also send a copy to VCS's solicitor. You will also receive a copy of their witness statement.
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Mustard11
post Wed, 24 Oct 2018 - 07:44
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Hi all

It’s been a while but I’ve finally got a court date. What sort of things do I have to compile for my court pack? I know I need to do a witness statement, but what else?

Many thanks
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ostell
post Wed, 24 Oct 2018 - 09:12
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Any other exhibits you want to bring to the attention of the court, referenced in your witness statement.
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nosferatu1001
post Wed, 24 Oct 2018 - 11:27
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Newbies thread
Post 2
Read it
Read it again
Bookmark it

Gives you a detailed list of what to do
WHen is your deadline for submission? WIthout any doubt, it WILL be on the court hearing letter.
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