Law360, New York (March 26, 2014, 9:06 PM EDT) -- The push to restrict collection of old debts is gaining steam. On March 11, 2014, the Seventh Circuit decided two federal Fair Debt Collection Practices Act appeals involving dunning letters offering to settle debts that were subject to a statute of limitations defense.[1] Although the court made clear that it is not "automatically improper ... to seek repayment of time-barred debts," it found that offers to "settle" a debt may falsely suggest that the debt is legally enforceable and thereby support claims under the FDCPA at least at the pleading stage.[2] Because the Third and Eighth Circuits previously held that such letters do not violate the FDCPA unless they expressly threaten litigation, there is now a split in the circuits and a possibility of U.S. Supreme Court review....