1:28 PM -- Melvin Townsend's attorney, Jake Jondle, tells TMZ Sports his client has been dealing with a myriad of injuries since the Mike Tyson attack ... including a concussion, cervical radiculopathy, and impaired vision.

"Not only is the evidence clear that Mr. Tyson committed the intentional torts of assault and battery, but he also acted recklessly and negligently," Jondle said in a statement to us Thursday.

"Additionally, Mr. Tyson admitted on national television to attacking Mr. Townsend and never once claimed a legal justification for his actions, such as self-defense. He admitted he should not have attacked Mr. Townsend. Being irritated by a fan is not a legal defense to any of Mr. Townsend's claims."

Jondle added that his letter this week to Alex Spiro was sent as simply an effort to "engage in good-faith settlement discussions to attempt to resolve this claim prior to filing a lawsuit."

The man who Mike Tyson pummeled during a wild fight on a plane last year is now demanding the boxer pay him nearly half a million dollars to avoid a future lawsuit over the altercation.

But, the boxing legend's attorney, Alex Spiro, is adamant the whole thing is "a shakedown" attempt ... and insists absolutely no payment will be forthcoming.

A lawyer for Melvin Townsend -- the punch victim -- made the demands clear in a pre-litigation letter sent to Spiro earlier this week, according to the New York Post.

In the document, the lawyer -- Jake Jondle -- said Tyson could have used other remedies to diffuse the situation on the April 2022 JetBlue flight ... but instead "he chose physical violence" and "viciously assaulted" Townsend.

Jondle explained as a result of the attack, Townsend sustained a "severe headache" as well as neck pain ... and "is still suffering with the effects of the assault to this day."

Jondle wrote in the document that $450,000 from Tyson would help Townsend cover his legal bills ... as well as any future treatment Townsend would require.

According to Spiro, however, no such check will be written.

"I have received a shakedown letter related to some instigator's harassment of Mike a year ago and the aftermath," Spiro said in a statement. "There will be no shakedown payment."

Reps for Tyson had previously told TMZ Sports the entire incident happened because Townsend threw a water bottle at the former pugilist and annoyed him repeatedly. Tyson himself later said on his "Hotboxin" podcast that Townsend "was f***ing with me" prior to the incident.

For Townsend's part, Jondle said in his letter this week his client was simply "excited to see [Tyson] on the flight, began discussing the marijuana industry and psychedelic mushrooms with him, and Mr. Tyson became annoyed" and attacked.

Tyson's been in the clear criminally, meanwhile, for over a year ... as prosecutors declined to file charges against the ex-fighter in May 2022.