Valle vs. First National Collection Bureau, Inc.

Valle vs. First National Collection Bureau (Southern District, Florida., May 17, 2017) – Case No. 16-cv-62751. Plaintiff, through attorneys Jibreal Hindi and Thomas Patti, claimed the bar code visible through the glassine window of our client’s envelope violated the FDCPA/FCCPA. Judge Robert Scola granted our Motion for Summary Judgment applying the “benign language exception” the Third and Eight Circuit Courts had applied in similar cases. In reaching his decision, Judge Scola stated: “§ 1692f(8) was intended to be limited to symbols indicating that the contents of the envelope pertain to debt collection … the Court does not find that the mere visibility of a bar code on an envelope containing a collection letter violates § 1692f(8).”

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