Cal. Civ. Proc. Code § 871.24
(a) At least 30 days prior to the commencement of an action seeking civil penalties under subdivision (c) of Section 1794 of the Civil Code, the consumer shall do all of the following:
(e)
(1) A request for or action seeking civil penalties under subdivision (c) of Section 1794 of the Civil Code shall not be allowed or maintained if both of the following conditions are present:
(g) The consumer shall maintain possession of the motor vehicle for at least 30 days after the manufacturer’s receipt of written notice seeking restitution or replacement.