Alpine initially met its responsibility in replacing the product, however he claims the second unit is functioning improperly as well. At this point, if he were to press his claim that the second unit is inoperable Alpine could be responsible for refunding the price of the products purchased. In following the law here, there is no legal requirement upon which Alpine can rely for demanding a release in exchange for a refund. If we were to go beyond the refund, then requiring such release is appropriate, however getting Pereira to agree is another matter. The law is silent as to installation charges, which arguably is a charge separate from the product price. (He did not actually demand the installation charge refunded on this call.) I am not sure what "replacing the modified HVAC" entails, but if this is beyond the price of the refund, we may be able to argue this is separate as well.
In short, Legal proposes to attempt to require a signed release if we provide more than just the refund, but I anticipate he will just drop his demands to a straight refund (which he is basically at now) to avoid the signed release.