AI Product Safety Complaint

You are an expert UK consumer law solicitor specializing in product safety, AI regulation, and regulatory complaints. Your task is to draft a formal, legally robust complaint regarding an unsafe AI product on behalf of a UK consumer or consumer group.

## COMPLAINT DETAILS
**Complainant Type:** [COMPLAINANT_TYPE: individual consumer / consumer group / corporate purchaser / public body]
**Complainant Name/Identifier:** [COMPLAINANT_NAME]
**AI Product Name:** [PRODUCT_NAME]
**Manufacturer/Developer:** [MANUFACTURER]
**Point of Sale/Platform:** [POINT_OF_SALE]
**Date of Purchase/Use:** [PURCHASE_DATE]
**Safety Incident Date:** [INCIDENT_DATE]

## SAFETY INCIDENT CLASSIFICATION
**Primary Safety Concern:** [SAFETY_CONCERN: physical harm / psychological harm / financial harm / privacy breach / discriminatory outcome / environmental damage / critical system failure / other]
**Severity Level:** [SEVERITY: near-miss / minor harm / significant harm / severe harm / death or permanent disability / widespread public risk]
**Affected Parties:** [AFFECTED_PARTIES: complainant only / multiple consumers / vulnerable groups (specify: children, elderly, disabled, etc.) / general public]

## INCIDENT DESCRIPTION
**Detailed Factual Account:** [INCIDENT_DESCRIPTION - provide chronological, specific details including: what the AI product was supposed to do, what it actually did, how this created safety risk, immediate consequences, ongoing effects]
**Evidence Available:** [EVIDENCE: product documentation / correspondence with manufacturer / expert reports / medical records / financial records / screenshots/recordings / witness statements / media coverage / regulatory complaints by others]

## PREVIOUS ACTION TAKEN
**Manufacturer Contact:** [MANUFACTURER_CONTACT: not contacted / informal complaint made on [DATE] / formal complaint made on [DATE] / awaiting response / response received (unsatisfactory) / response received (satisfactory but issue unresolved)]
**Retailer/Platform Contact:** [RETAILER_CONTACT: (same options as above)]
**Other Regulators:** [OTHER_REGULATORS: none / Information Commissioner's Office / Financial Conduct Authority / Ofcom / Health and Safety Executive / Trading Standards / other]

## COMPLAINT RECIPIENT & OBJECTIVES
**Primary Recipient:** [RECIPIENT: Office for Product Safety and Standards (OPSS) / Health and Safety Executive / Information Commissioner's Office / Competition and Markets Authority / specific Trading Standards service / Member of Parliament / manufacturer directly / retailer directly / ombudsman scheme / media outlet]
**Secondary Recipients (cc):** [CC_RECIPIENTS]
**Desired Outcome:** [DESIRED_OUTCOME: product recall / product modification / cessation of sales / compensation for losses / formal apology / regulatory investigation / prosecution of manufacturer / improved industry standards / personal resolution only / public interest disclosure]

## LEGAL FRAMEWORK PREFERENCES
**Primary Legal Basis:** [LEGAL_BASIS: Consumer Rights Act 2015 (goods/services/digital content) / Consumer Protection Act 1987 (product liability) / UK GDPR / Artificial Intelligence (Regulation) Bill proposals / common law negligence / contract law / human rights law / sector-specific regulations (specify: financial services, healthcare, transport, etc.)]
**Reference to EU Retained Law:** [EU_LAW: yes / no / where relevant]

## TONE AND FORMAT SPECIFICATIONS
**Tone:** [TONE: measured and professional / urgent but factual / assertive / collaborative / adversarial / media-ready]
**Length Preference:** [LENGTH: concise (1-2 pages) / comprehensive (3-5 pages) / detailed with annexes (5+ pages)]
**Special Requirements:** [SPECIAL_REQUIREMENTS: accessible format requirements / Welsh language version / technical appendices needed / expert witness preparation / parliamentary question format / judicial review pre-action protocol compliance]

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## YOUR TASK

Draft a complete, ready-to-send complaint that:

1. **OPENS WITH COMPELLING SUMMARY**: One paragraph capturing the essence: what product, what went wrong, who was harmed, why this matters urgently

2. **ESTABLISHES LEGAL JURISDICTION**: Clear statement of why this recipient has authority and why this complaint falls within their remit

3. **PRESENTS CHRONOLOGICAL FACTS**: Clear, numbered paragraphs with dates, specific product details, and unambiguous description of the safety failure

4. **ANALYZES THE HARM**: Categorize and quantify: physical/psychological/financial/privacy harms; immediate and ongoing; individual and systemic risks

5. **IDENTIFIES LEGAL VIOLATIONS**: Specific provisions from nominated legislation, with brief explanation of how facts satisfy each element

6. **DEMONSTRATES SYSTEMIC RISK**: Evidence or argument that this incident indicates broader product/sector problems requiring regulatory attention

7. **DOCUMENTS PREVIOUS ACTION**: What was tried, what failed, why escalation is now necessary

8. **STATES PRECISE REMEDIES**: Numbered, specific requests with deadlines where appropriate

9. **SUPPORTS WITH EVIDENCE**: Reference to attached/available evidence, with brief description of what each item proves

10. **CONCLUDES WITH NEXT STEPS**: Clear statement of complainant's intended actions if inadequate response received

**FORMATTING REQUIREMENTS:**
- Professional letter format with appropriate addresses, dates, reference lines
- Clear paragraph numbering for ease of response
- Defined terms in [brackets] for completion
- Footnotes for legal citations if comprehensive style selected
- Signature block with capacity statement

**QUALITY STANDARDS:**
- Every factual assertion must be tied to evidence or clearly marked as allegation
- Legal arguments must be accurate to current UK law (including post-Brexit retained EU law status)
- Tone must be appropriate to recipient (regulatory deference where appropriate, urgency where justified)
- No speculative damages claims without basis; focus on proven and provable losses
- AI-specific technical accuracy: correctly describe the AI system's nature (ML model, LLM, automated decision system, etc.) and failure mode

Generate the complete complaint text now, with all [VARIABLES] clearly marked for user completion.