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As the formula is not publicly known, it's impossible to answer the question.
I strongly recommend you heed their advice. That is the first warning. If you keep doing that, Valve can and will remove your refund privilege, permanently.
Perhaps if there was some issue with a handicap and controls etc..
But the system is not intended for you to just try games... it is more about if your hardware is good with it.
I normally return games if they have control issues with a joystick since I can't use a keyboard for very long in active games.
You got a warning more for the reason you gave them, not number of games.
I will do look into review more now before buying.
Research more before you ever consider purchasing, as another said; they can permanently revoke the ability to make refunds if you're seen as abusing it. You can see how general performance will be before you make a purchase by searching the CPU/GPU and the name of the game on YT as example, read reviews, see livestream/gameplay videos.
Getting even the first warning is letting you know they believe it's being abused, and is a courtesy that if continued they will revoke the ability permanently.
So, buy 4 games, refund 3 in a short while, you get the warning.
Buy 10 and refund 3 in a short while, no warning.
There are 2 stages to the warning. You got the first one. If you still continue to refund at that pace you will get a second warning which is sharper in its wording.
Only if you then still ignore the warning and continue to refund you will be banned from the refund system.
As for your first warning, simply stop refunding for a while and buy a few games and keep them, then the warning will disappear when you refund something the next time.
Example only:
You will face consequences if:
Abused report and refund system.
Insulting member.
Bounce check or when they unable get payment.
You may face consequences if:
Modifying achievements.
Argue with mods.
Didn't read the ToS or rules.