Court Grants Debt Collector Summary Judgment in FDCPA Claim Based on Collection Letter With Multiple Addresses

Editor's NoteThis article, authored by Mark Kundmuller and David Gettings of Troutman Pepper, previously appeared on Troutman Pepper’s Consumer Financial Services Law Monitor and is re-published here with permission

In Bacalzo v. Credit Control, LLC, No. 20-16904 (KMW/MJS) (D.N.J. June 7, 2022), the court granted summary judgment in favor of a debt collector who included multiple contact addresses in a debt collection letter.

Defendant Credit Control LLC (Credit Control) sought to collect a credit card debt owed by plaintiff Linda Bacalzo. As part of its efforts, Credit Control sent the plaintiff a letter requesting payment. This letter listed Credit Control’s post office box and a street address, as well as its website, as its contact information.

The plaintiff filed suit under the Fair Debt Collection Practices Act (FDCPA), asserting that because the collection letter contained multiple addresses, the least sophisticated debtor would be confused or misled as to which address to send his/her debt dispute.

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