Traffic ticket-fighter, Todd Dube, says he will launch a class action lawsuit against the City of Winnipeg by early February and will seek a full refund of roughly 35,000 parking tickets issued under the Know Your Zone program.

Dube, co-founder of Wise Up Winnipeg — a group that advocates for people who get traffic tickets, believes all tickets issued under Know Your Zone, regardless of the time, are illegal. A full refund on those tickets is worth roughly $3.3 million, according to his estimates.

In mid-December, Dube told City of Winnipeg officials they had a month to respond to a letter that outlined his legal reasoning.

"We gave them until January 15 and we didn't hear anything back from them," said Dube.

"It seems the only way to communicate with the City of Winnipeg is through the courts."

Winnipeg's bylaw 'ridiculous,' says Dube

Dube believes Know Your Zone tickets are invalid because no street signs are installed to warn drivers parking bans are in place.

"The City, under the Highway Traffic Act, is required to use signage to make motorists reasonably aware of parking restrictions," he said.

Winnipeg must have hoped motorists would accept the rules and pay the fines, Dube said.

"They think they afforded themselves the right to simply ticket you and tow you, well, I got one of those tickets and I knew that nobody could do that," he said.

"The Highway Traffic Act clearly protects people from such dubious actions." - Todd Dube

"It's ridiculous...We pursued the law on it and as I expected, the Highway Traffic Act clearly protects people from such dubious actions."

A City of Winnipeg spokesperson told CBC Thursday they are still in discussions with the province about the legality of Know Your Zone tickets.

"I can tell you that discussions with the Province are ongoing, but that there is no further update at this time to what was provided in the December 11 news release," the spokesperson wrote in an email.

Full version of the City of Winnipeg's release from Dec. 11, 2015:

For Immediate Release

Friday, December 11, 2015

Winter parking bans update

Tickets to be issued from 11:00 p.m. to 6:00 a.m.; residents still need to "Know Your Zone" and move your vehicle at the appropriate times

Winnipeg, MB – This winter, the City of Winnipeg is proceeding with all winter parking bans as usual with one change – tickets will only be issued from 11:00 p.m. to 6:00 a.m. The reason for this change is that the Highway Traffic Act only permits ticketing without signage during this timeframe and the City's winter parking bans extend beyond these hours. This recently came to the City's attention and officials are working to correct this by collaborating with the province on a resolution.

In the meantime, residents still need to "Know Your Zone," be mindful of snow routes and move their vehicle at the appropriate times. Even though the City will only be ticketing from 11:00 p.m. to 6:00 a.m., residents are encouraged to move their vehicles when a ban is in place regardless if they will receive a ticket or not. This will ensure streets are properly cleared.

"We need your cooperation so that we can deliver the high quality snow clearing service that we know Winnipeggers expect," said Michael Jack, Chief Operating Officer. "We don't want to issue any tickets. We want people to move their cars at the specified time so that our streets can be cleared quickly and efficiently."

The Know Your Zone system will continue to be used for residential parking bans, if one is needed. This means that all residential streets will continue to have a snow zone letter and zones will be plowed in 12-hour shifts, around-the-clock. However, the City will only be issuing tickets from 11:00 p.m. to 6:00 a.m. during the residential parking ban. Vehicles will continue to be courtesy towed on a 24-hour basis.

For the annual snow route parking ban or any declared snow route parking ban that may be required, tickets will only be issued until 6:00 a.m., instead of the usual 7:00 a.m., on snow routes.

Further information is available at City of Winnipeg – Winter Parking Bans Update