Hicks vs. Client Services, Inc. (S.D. Fla. December 11, 2008) – Case No. 07-cv-61822. Plaintiff filed a class action lawsuit alleging that our client, a debt collection agency, violated the Fair Debt Collection Practices Act and the Telephone Consumer Protection Act. In refusing to certify the Plaintiff’s proposed TCPA class, the court found that the issue of prior express consent was one which required an individualized inquiry, and thus class certification of the Plaintiff’s TCPA claim was improper for lack of commonality and predominance.