Consumer complaint received 2025-12-24 00:00:00
Product: Money transfer, virtual currency, or money service — Mobile or digital wallet
Issue: Unauthorized transactions or other transaction problem — 
Company: Paypal Holdings, Inc
State: NY

Complaint narrative:
MASTER DEMAND & CIVIL COMPLAINT PACKAGE ( PayPal , Inc. Business Account Misconduct ) PLAINTIFF XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX NY XXXX Phone : XXXX Email : XXXX DEFENDANT PayPal , Inc . 
XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX JURISDICTION & VENUE This action is brought in XXXX XXXX XXXX XXXX XXXX pursuant to CPLR 301, 302, and 210. 
The amount in controversy is {$25000.00}, exclusive of costs and interest. 



NATURE OF THE ACTION This action arises from unauthorized deductions, improper chargeback enforcement, failure to investigate fraud, continued withdrawals after revocation of authorization, and systemic misconduct by PayPal , Inc., resulting in financial loss, emotional distress, reputational damage, and business disruption.

FACTUAL BACKGROUND ( CHRONOLOGICAL ) 1. Plaintiff operates a legitimate small business utilizing PayPal for payment processing.

2. On XX/XX/XXXX, Plaintiff paid {$300.00} via PayPal ( Account : XXXX ) for a 30-day music promotion campaign that was never performed.

3. Fraudulent actors later generated fake transactions and traffic, triggering a PayPal chargeback of {$500.00}, for which Plaintiff was wrongfully held responsible.

4. PayPal subsequently issued a bill for {$520.00}, later reduced to {$470.00}, while continuing to deduct funds without authorization. 
5. Plaintiff sent multiple certified letters demanding cessation of deductions on : XX/XX/XXXX XX/XX/XXXX XXXX. Despite written revocation of authorization, PayPal continued deductions including : XXXX deductions : {$7.00}, {$5.00} XXXX deductions Misc. administrative offsets 7. During the week of XX/XX/XXXX, Plaintiff spent over two hours on the phone with PayPal representatives, including senior personnel who admitted the situation was not right but claimed the system could not be overridden.

8. Plaintiff was repeatedly told PayPal could do nothing demonstrating reckless disregard and systemic failure.

9. Plaintiff never authorized continued deductions and explicitly demanded they stop.

10. Plaintiff has suffered business disruption, stress, reputational harm, and financial loss.

SYSTEMIC MISCONDUCT ALLEGATIONS PayPal maintains an automated dispute and chargeback enforcement system that prioritizes internal convenience over consumer protection, treating small business users as expendable assets. Even after notice, documentation, and verbal admissions of error, PayPal refuses corrective action constituting institutional negligence and systemic misconduct.

CAUSES OF ACTION COUNT I Unauthorized Withdrawals/ Conversion PayPal deducted funds without authorization after express revocation.

COUNT II Negligence Failure to properly investigate fraud and prevent continued harm.

COUNT III Breach of Implied Covenant of Good Faith PayPal knowingly enforced improper deductions.

COUNT IV Unfair & Deceptive Business Practices Violation of consumer protection principles.

COUNT V Emotional Distress Prolonged financial stress tied to Plaintiffs livelihood.

DAMAGES ( ITEMIZED ) Direct Financial Loss Chargebacks & deductions : {$1000.00} Lost Productivity & Business Interruption 10+ hours @ $ XXXX = {$1500.00} 10 days disruption @ $ XXXX = {$2500.00} Administrative Costs Certified mail, printing, compliance : {$300.00} Pain & Suffering Emotional distress, anxiety, reputational harm : {$5000.00} Statutory / Equitable Damages Failure to investigate , continued enforcement : {$4700.00} Injunctive Relief Valuation Accounting, correction , prevention XXXX {$5000.00} Punitive / Exemplary Damages Reckless disregard after notice : {$5000.00} TOTAL DAMAGES DEMANDED {$25000.00} INJUNCTIVE RELIEF REQUESTED Plaintiff seeks an order : 1. Permanently prohibiting PayPal from making deductions without express written authorization.

2. Requiring immediate restoration of Plaintiffs account to good standing.

3. Mandating a full accounting of all deductions and reversals.

4. Enjoining further automated enforcement of disputed transactions.

RESERVATION OF RIGHTS All rights reserved without prejudice pursuant to UCC 1-103, 1-207, 1-308. Plaintiff does not waive constitutional, statutory, or equitable protections.

SETTLEMENT DEMAND Plaintiff offers to resolve this matter for {$25000.00} within 30 days. 
Failure to resolve will result in civil litigation, arbitration, discovery, and regulatory complaints. 



VERIFICATION I affirm under penalty of perjury that the foregoing is true and correct. 



DATED : ______________________ SIGNED : XXXX XXXX XXXX ( All Rights Reserved ) XXXX XXXX XXXX XXXX XXXX Authorized Representative XXXX XXXX XXXX XXXX. 




Notary

Company response to consumer: Closed with non-monetary relief