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minimum rating for buyers?

When making an auction can you restrict or limit winners to a minimum rating? I recently put an auction up, which was won by a person with a rating of (1) after the sell, sent the item, and he asked for a refund claiming the item I sent him is fake (not as described).

 

It is currently under disbute, but quite frankly win or lose this is leaving a very bad taste for me.

 

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