Foster

I. INTRODUCTION

Defendant Keith Williams appeals the unlawful detainer judgment in favor of plaintiff Jennita Foster doing business as Guest House Management. Defendant contends the judgment should be reversed because the three-day notice to pay rent or quit concerning his apartment unit failed to comply with Code of Civil Procedure section 1162, subdivision (2). As discussed below, we reverse the judgment.

1 The three-day notice did not comply with Code of Civil Procedure section 1162, subdivision (2)’s requirement that the notice provide the “address of the person to whom the rent payment shall be made” because the notice listed a uniform resource locator (URL) address, as opposed to the address of a physical place where the rent had to be paid. The notice also did not comply with Code of Civil Procedure section 1162, subdivision (2), because it failed to state that payment could be made pursuant to a previously established electronic funds transfer procedure.

II. FACTUAL AND PROCEDURAL BACKGROUND

Plaintiff’s unlawful detainer action proceeded to trial based on a three-day notice to pay rent or quit. The three-day notice indicated it was served on defendant on June 24, 2013,…