[ON YOUR LETTERHEAD]

WITHOUT PREJUDICE SAVE AS TO COSTS

Name and address of other party's solicitor

Dear insert contact name

Insert subject of letter

1 We refer to our letter of insert date OR open letter of today's date regarding the dispute between our respective clients in relation to insert details of the dispute, e.g., our client's repudiation claim. As set out in that letter, both we and our client are confident that it will be successful should this matter go to arbitration OR trial OR your client's claim is unsustainable. Nonetheless, our client is mindful of the obligations on parties to try to resolve their disputes amicably and of the potential benefits to it, in terms of costs, of making a settlement offer. Our client is, therefore, prepared to make the settlement offer set out below.

2 In the interests of resolving this matter, [but without accepting that it has any liability,] our client is prepared to settle on the following terms:

• 2.1 insert details of settlement—see the drafting notes for guidance on issues to consider