Go on YouTube, and look for a fantastic talk named "**** you, pay me". All that needs to be said is said there, and then some :)

A) The first thing you should do is explain that after all of this work being done, and after he has had the opportunity to both see the new website and possibly photograph it to have someone else do it for cheaper, that no refunds will be given. Explain youve done substantial work, exact to his specs. HOWEVER, TELL HIM IN TEXT OR EMAIL WRITING (THE FORM HE BEST WANTS TO COMMUNICATE WITH) THAT YOU WILL EDIT THE WEBSITE AGAIN, FOR FREE, TO HIS LIKING, HOWEVER HE WANTS... But that no refunds will be given. Explain legally, you are not obligated to give a refund. B) Just a heads up- In the future, you either shouldn't offer 100% satisfaction guarantee- or if you do, you should have a clause in your contracts that say "we offer 100% satisfaction guarantee of websites, meaning that if customer is not satisfied with website layout or design, we will fix it until customer is satisfied, in one set of changes, not to exceed 72 hours of demands for change. HOWEVER, no refunds will be given after work has commenced, because that would cause me/our company to be taken advantage of. By signing, customer agrees to these terms." B) If he refuses to allow you to fix things, and refuses to say exactly "what he wants changed" and he just keeps yelling that he wants all his money back.. Then you should politely text/email him "You can sue me if you would like. You are allowed to pursue whatever avenue you wish. However, I have done nothing wrong. You agreed to the mock-website design and I provided the website exactly as you wanted. Then, I offered to edit the website further, for free to your satisfaction, and you are refusing to allow me to help you make this website how you "claim" to want. Instead, you are only wanting all your money back. What is really occurring is you are probably wanting to scam me and get money for free. Feel free to take it to small claims, but I will bring all the documentation and you will, as far as I can tell, not win anything. But if you'd like to waste hours of your time and the courts time, then go ahead." C) IMPORTANT NOTE: I DO NOT RECOMMEND DOING WHAT SOMEBODY ELSE SUGGESTED, WHICH IS "CALLING HIS BLUFF AND OFFERING A REFUND, BUT ALSO OFFERING TO DELETE THE WEBSITE"- AND HERE IS WHY: He has already probably found somebody cheaper who is willing to rebuild the website to exactly how you made it. He probably took pictures of all your hard work, and is gonna pay somebody significantly less to quickly rebuild what you made. That is how scammers like him work. He's a shiester. DO NOT OFFER TO REIMBURSE HIM- BECAUSE IF YOU CALL HIS BLUFF AND OFFER TO REIMBURSE/DELETE THE SITE, AND HE SAYS "OK FINE" AND THEN YOU GO BACK ON YOUR OFFER... THEN LEGALLY, YOU ARE SCREWED! Because at that point, you will have offered to reimburse, and then violated your agreement you gave him. In writing, or even over phone, that would be viewed as a written or oral contract. In small claims court, he will need to prove that there was a material breach of contract, or will need to prove damages, or will need to prove he did not get what he was offered. None of this scenarios apply here. The plaintiff is the complaining party in a complaint, and has the burden to prove the claims in the complaint; the defendent is the complaining party in a counterclaim and has the burden to prove the claims in the counterclaim. The burden of proof in small claims court is a preponderance of the evidence. 1) If he sues you, the most he will be able to get is his money back anyway; no more, no less. Unless there was like serious extenuating circumstances (which there arent) So for this reason alone, you shouldn't offer to reimburse him at all. 2) If he sues you, just bring the proof that it's exactly what he wanted, and then you will win the case about 95% of the time. Of course, dress in a suit, respect the judge, speak clearly, be prepared and bring all necessary documents. I own a painting/remodeling company and I deal with shiesters like this guy all the time. In fact, I'm dealing with one of them today. So trust my advice. It's 100000x better than probably 99% of the people on FML on something like this. My advice is valuable, so take it

Oh- and again, to reiterate, once you sign a contract, he has an obligation to pay you the full amount, and you have an obligation to provide him with what you offered. By you offering to edit the site to his liking, in a TIMELY MANNER (offering to fix it today or tomorrow), then it completely removes any right of his to take you to small claims court or ask for a refund! I mean, legally he can TAKE YOU to small claims court, yeah, but he wont WIN though. You shouldn't be scared or worried or shaking. You are in the right. The important thing is to remain calm, be educated on the law. Knowledge drives out fear. The more you know, the less worried you have to be. Usually the people who are worried about threats like this, are people who don't have a good grasp on the ins and outs of the law. Also: If you tell him what I said in the post above, exactly as I described it- I can bet you 99% likely he does not take you to small claims court. In fact, the fact he is making threats to "take you to small claims" over this, shows he probably has very little knowledge of the legal system anyway. OR if he does know it, he already knows that he is BLUFFING. Either way, he either wont carry it out, or he will be a bumbling idiot in small claims and lose.

being in the creative fields myself, i sure hope you git him to sign off everystep of the way? this will protect you from these kinds of things...

Tell him you'll give him the refund as soon as you finish taking down all the work you put on it first.