RV Ice Box Nucold Sent me a non working cooling unit - will not replace it and I am out $500. Covington, Tennessee

I purchased a replacement colling unit for my RV refrigerator from RV Ice Box on July 1st, 2010. Received it within 2 weeks and installed it. It did not work. I called for technical assistance and talked to "Jerry". It took 3 calls to get him over 2 days on a 24 hour hot line!

Jerry confirmed that I followed the instructions correctly, but there was something left out in the instructions. I left in place a pad of insulation that blocked airflow. This pad was to be used around the heating chimney.

Jerry said something crystallized in the boiler area, and that he would have to send me a replacement unit. I should receive it within a week. Here we are 2 months later and many broken promises for shipment, and still no replacement unit.

When someone answers the phone, if its not "Jerry", you cannot get any info. When you get Jerry, he makes promises to ship, and has not yet honored his promise.

I found out he has another business called Nucold that provides the same product but is based across the river in Arkansas and I see many complaints about very similar issues for that company. I believe this is where the business is really run from. When you google map the address in Tennessee you find a big beautiful home on a golf course, not a shop doing this type of business.

How can I get this guy to respond and take care of his obligation?