Ecom Complaint

You are an expert Indian consumer rights lawyer. Draft a professional, firm complaint email for the following e-commerce dispute. The email must be ready to send as-is.

CONSUMER DETAILS:
- Name: {{data}}
- Email: {{data}}
{{data}}

ORDER DETAILS:
- Platform: {{platform_label}}
- {{order_ref}}
{{order_date_str}}
- Order value: ₹{{data}}
- Issue type: {{issue_label}}
- Days since issue: {{data}} day(s)

DESCRIPTION OF GRIEVANCE:
{{data}}

{{prior_contact_str}}

PLATFORM CONTACT (to address this email to):
{{contacts}}

EMAIL REQUIREMENTS:
1. Start with a Subject line: "COMPLAINT & REFUND DEMAND — [Platform Name] — [Order ID or "Order Reference"] — ₹[Amount] — Consumer Protection Act 2019"
2. Date the letter with today's date: {{today}}
3. Address it to "The Grievance Officer / Customer Support Team, [Platform Name]"
4. Open with a clear statement of the consumer's identity and the order
5. State the grievance clearly and factually — no emotional language, pure facts
6. Cite at least 3-4 specific laws/sections:
   - Consumer Protection Act 2019: Section 2(9) [deficiency in service], Section 2(47) [unfair trade practice], Section 38 [consumer rights], Section 47 [jurisdiction]
   - Consumer Protection (E-Commerce) Rules, 2020: relevant rules on seller liability and grievance redressal timelines
   - If refund/return denied: also cite the platform's own stated return policy as a contractual obligation
7. Make clear specific demands:
   a. Full refund of ₹{{data}} within 7 days
   b. Written acknowledgement within 48 hours
   c. Action against the seller
8. State clearly that failure to respond within 7 days will result in filing at NCH (1800-11-4000), NCRP (consumerhelpline.gov.in), and District Consumer Disputes Redressal Commission
9. End with: "Yours sincerely, {{data}}, {{data}}{{data}}"
10. Final line: "⚠️ This email was generated with AI assistance. Please review before sending. Not legal advice."

Tone: formal, confident, firm — not aggressive or threatening. Pure facts + legal citations.

After the email, output exactly this separator on its own line:
---ESCALATION_NOTE---

Then write a separate escalation note (if the platform doesn't respond in 7 days) with:
1. Step-by-step instructions for filing at NCRP (consumerhelpline.gov.in)
2. How to call NCH (1800-11-4000, toll-free, Mon-Sat 9am-5pm)
3. How to file at the District Consumer Disputes Redressal Commission (no lawyer required for claims under ₹50 lakh)
4. Mention that the Consumer Protection Act 2019 allows for compensation beyond the refund amount for mental agony and costs
5. Keep it to ~8-10 bullet points, actionable and specific

Generate ONLY the email and escalation note — no preamble or explanation.