MGL Chapter 93a demand letter to HP about my C5280

By | April 14, 2008

__ ___ Street
____, __ _____-____
Fax: ___-___-____
Phone: ___-___-____

April 14, 2008

Fax: ___-___-____

Ref: HP case manager ID # __________ (previously __________)

To whom it may concern:

This is a demand letter as required by Chapter 93a of the General Laws of Massachusetts.

In August 2007, I purchased an HP C5280 All-In-One unit directly from HP, via the HP Shopping Web site.

My primary reason for purchasing this unit was to be able to produce high-quality digital prints at home.

The unit has failed to produce a single high-quality digital print since the day I bought it, despite many attempts.

Every single print produced by the unit has visible streaks across the entire print, because some of the ink jets in the photo ink cartridge are not working properly. Every single self-test page produced by the unit has visible gaps in the test patterns for the photo cartridges, thus visibly and obviously confirming that some of the ink jets in the photo cartridges are not working properly.

HP case managers have sent me two replacement units which are still in my possession. Neither of them has solved the problem. They have sent me several replacement ink cartridges. None of them has solved the problem. They have sent me new photo paper. It did not solve the problem.

I have tried cleaning the ink cartridges using the C5280’s setup menu. I have tried cleaning the ink cartridges as instructed by HP technical support engineers. I have tried cleaning the contacts on the ink cartridges and inside the printer as described on the HP Web site. None of this has helped. Frankly, if it did help, that would indicate an absurdly unreliable printer and ink cartridges, since these problems have occurred with brand new cartridges and new and newly refurbished C5280 units.

I have wasted over nine hours of my time troubleshooting this issue, setting up replacement units, and testing replacement units and ink cartridges. I have also wasted a huge amount of ink from working ink cartridges (since a possibly defective cartridge cannot be tested without using ink from a working cartridge at the same time); paper used to print alignment and self-test pages; and photo paper.

The HP Web site claims that the C5280 produces “lab-quality snapshots.” Every single print the C5280 has produced for me has been visibly and obviously inferior to a print of the same digital images produced at my neighborhood drug store. This would be true even if the C5280 were working perfectly – even aside from the streaks, the prints produced by the C5280 are visibly inferior to the drug-store prints. The claim of “lab-quality snapshots” is therefore false advertising, which is illegal under Massachusetts law.

The HP Web site also claims that the C5280 comes with a “one-year warranty,” but clearly HP does not actually honor that warranty, because HP’s case managers have been unable to resolve my problem and yet have repeatedly refused to take back my original C5280 unit, the two replacement units, and all of the photo paper and ink cartridges I have purchased directly from HP and refund my money.

I have also asked repeatedly for an HP technician to be dispatched to my house to resolve the problem on-site, since my case managers’ attempts to resolve the problem through remote troubleshooting have failed and have therefore done nothing but waste my time. This request has also been repeatedly refused.

In short, HP has engaged in false advertising of the C5280, has sold me a defective product, has failed to address the defect, and has refused to refund my money.

Here are your options for resolving this problem to my satisfaction:

  1. Send a trained HP printer technician to my house to troubleshoot and resolve the issue. If the technician is unable to resolve the issue in a single visit, he must leave with my original C5280 unit, the two replacement units, and all of the ink cartridges and photo paper I purchased from HP, and present to me before he leaves a check for $285.64 to fully reimburse me for the purchase cost of all of these items.

  2. Mail me a refund check for $285.64 and send a delivery service to my home at your expense to pick up the three printer units and all of the ink cartridges and photo paper. Please note: I will not allow any of these items to be picked up to be returned to HP until I have the refund check in my hand.

  3. Mail me a refund check for $285.64 and confirm in writing that you do not want back the three printer units or supplies, and I will dispose of them myself.

If you are unable to resolve this problem to my satisfaction within thirty days, I will have no choice but to file suit against HP to recover not only the $285.64 I’ve spent trying to print photos with the C5280, but also $___ in compensation for the time I’ve spent trying to resolve this problem, plus the $40 small-claims filing fee, plus triple damages for HP’s multiple violations of M.G.L. Chapter 93a, for a total of $_,___.__ plus interest.

In addition, I will find every single Web site on the Internet which discusses the C5280 and allows users to post their own reviews, and I will post a review on every single one summarizing my terrible experience and giving the C5280 the lowest possible rating.

This letter and all previous documentation of my problem with the C5280 are fully documented at

I look forward to your prompt response.


Jonathan Kamens


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