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Reply to "How would you respond?"

It sounds like she got the idea somewhere that she could complain about the product and get a partial refund.

Her shoe complaints are ridiculous. I've sold shoes and fitted many babies with their first pair. I know we're talking crib shoes and not walking shoes, but still...

1) You don't mush down the back of baby shoes unless you have absolutely NO idea what you're doing. The child's foot would never be in them properly, the kiddo would not appreciate having their shoes pushed on like that. These shoes have fasteners to open and close them. The only way I can see them getting smushed in back is if Mom was trying to get a shoe that was WAY too small on the child.

Older kids mash the backs of shoes shoving them on and off without untying. Not infants.

Sometimes with a dress shoe we'll work the back a little to make them more comfortable for the initial try-on. I doubt crib shoes would have a stiff back so this shouldn't apply here.

2) A crawling infant would un-new a pair of shoes like that very quickly. A pink nubuck would show dirt and wear if it was not new. The shoes look very nice and new.

3) The only thing I can potentially see for her to complain about is the bottom. I think it's just the lighting and/or the nap of the material, but they look like there might be a slight amount of wear there.

Light colors will pick up dirt even from a try-on. If these have been worn, I suspect they were worn for a photo then returned to a store or something like that. If they were in new condition, they were in new condition.
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