You are a legal executive for the law firm, Messrs. TM Chan & Co.John Chan("John") approached you for advice in relation to a breach of contract case against Peter Law ("Peter"). Pursuant to the contract, John was toselland Peter was to buy100 pairs oflimited edition sneakersat the price of HK$1 million. The payment had to be settled within 30 days of delivery. The sneakers were delivered to Peter's residence in Tai Po on 1 September 2019. The time for payment has expired and Peter has refused and/or failed to pay John for the sneakers. John made numerous requests for payment, but to no avail. As such, John wishes to commence legal proceedings against Peter.

1.Advice John on any pre-action considerations before issuing legal proceedings against Peter.