Claim form received

Robbingthieves

I received this claim form 

I did not receive any PCN 
my car was registered to my old address in n.ireland and not updated as I was selling it
I am not aware of any PCNs being received at previous address 
I was living in apartment block in London with shared post box  at date of alleged incident but moved to new address in August 24 . The court claim is addressed to my current address
I have sent an AOS and need to start my defence . I have read lots of relevant threads and am checking is there any specific argument I need to quote
 POFA2012 ?
 Keeper but not driver ?
I realise it is my responsibility to update DVLA address but as a consequence I have not been able to respond or defend this prior to the court claim 
Any advice greatly appreciated 

Gr1pr

Do the same thing as the other recent april only DCB Legal claims on here,  similar recent paragraphs 2 & 3 , but dont mention not being the driver unless it definitely wasn't you

Post your proposed paragraphs 2 & 3 below , for critique,  plus post the issue date from the top right of the claim form too

Coupon-mad

Just use the template defence. If stuck what to put in para 3, why not read ten other DCB Legal Euro Car Parks threads exactly like yours? All the same really!