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LEGAL DEFENSE DOCUMENT: WRONGFUL BANK CHARGEBACK 1. EXECUTIVE SUMMARY [YOUR BUSINESS NAME]'s non-delivery of goods to [CUSTOMER NAME] in the amount of $[AMOUNT] was caused by documented government restrictions that legally excused performance under UCC § 2-615 (Fla. Stat. § 672.615). The Supreme Court's ruling in Learning Resources Inc. v. Trump, 607 U.S. ___ (Feb. 20, 2026) established that the IEEPA tariffs causing the disruption were unconstitutional — meaning [YOUR BANK] is attempting to shift financial losses caused by an illegal government act onto a small business merchant. 2. FORCE MAJEURE CHRONOLOGY Dec 3, 2024: MOFCOM Announcement No. 46/2024 — first critical minerals export controls on gallium, germanium, antimony. Feb 1, 2025: Executive Order 14195 — IEEPA invoked, 10% tariff on all Chinese goods. Apr 2, 2025: "Liberation Day" — sweeping reciprocal tariffs under IEEPA. Combined rate on Chinese goods: 145%. Apr 4, 2025: MOFCOM Announcement No. 18/2025 — seven categories of rare earth elements placed under mandatory export licensing. GACC authorized to physically detain containers at Chinese ports. May 28, 2025: US Court of International Trade rules IEEPA tariffs illegal. Oct 1, 2025: US Government Shutdown #1 begins. SBA Surety Bond Guarantee Program goes zero-operational. Oct 9, 2025: MOFCOM Announcements Nos. 55-62/2025 — six coordinated export control announcements covering entire rare earth supply chain. Feb 20, 2026: SUPREME COURT RULES 6-3: IEEPA DOES NOT AUTHORIZE TARIFFS. Learning Resources Inc. v. Trump, 607 U.S. ___ (2026). Chief Justice Roberts: "IEEPA contains no reference to tariffs or duties." 3. LEGAL AUTHORITY • UCC § 2-615 / Fla. Stat. § 672.615: Merchant's performance excused by government action. Third prong: compliance with government orders excused "whether or not later proved invalid." • 15 U.S.C. § 1666i (FCBA): Applies ONLY to consumer credit — inapplicable to B2B contracts. No federal appellate decision extends § 1666i to commercial supply agreements. • COGSA 46 U.S.C. § 30701: "Restraint of Princes" — MOFCOM/GACC physical detention of goods at Chinese ports. • FDUTPA Fla. Stat. § 501.204, § 501.2105: Attorney fee-shifting to bank upon judgment. • CFPB Circular 2024-03: Boilerplate shifting pre-modeled risk = unfair practice. • Pizza Hazel, Inc. v. Am. Express Co., Case 1:24-cv-12505-AK (D. Mass. Sept. 19, 2025): Arbitration clause void ab initio where unilateral modification permitted. ─────────────────────────────────────────────── ═══ DRAFT ═════ ATTORNEY REVIEW RECOMMENDED ═════ DRAFT ═══ ─────────────────────────────────────────────── FORMAL DEMAND LETTER Unlawful Right of Offset / Wrongful Chargeback Enforcement [DATE] VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED AND ELECTRONIC DELIVERY TO LEGAL DEPARTMENT [YOUR BANK] Attn: Legal Department / Dispute Resolution Division Re: FORMAL DEMAND FOR IMMEDIATE REVERSAL OF UNAUTHORIZED ACCOUNT OFFSET Account No.: [MERCHANT ID] Amount in Dispute: $[AMOUNT] [YOUR BUSINESS NAME] ("Merchant") hereby provides formal written notice that the above-referenced account offset is unlawful, procedurally defective, and without legal or contractual basis. Merchant demands the immediate and complete reversal of all funds debited within ten (10) business days. Pursuant to FDUTPA (Fla. Stat. § 501.2105), all attorneys' fees and costs incurred in prosecution of this matter are recoverable upon judgment. The cost of resolution increases substantially upon filing. This letter represents the lowest-cost resolution available to the bank. cc: [ISSUING BANK] cc: [PAYMENT PROCESSOR] cc: CFPB (filed simultaneously) cc: FTC (filed simultaneously) cc: OCC (filed simultaneously)