FDCPA Takeaways From 3rd Circ. QR Code Opinion

Law360 (September 12, 2019, 5:44 PM EDT) -- It’s easy to look at the U.S. Court of Appeals for the Third Circuit's August Fair Debt Collection Practices Act decision in DiNaples v. MRS BPO LLC as a straightforward application of existing precedent. But a deeper look sheds light on FDCPA litigation generally and fighting claims under Section 1692f(8) in particular.

In DiNaples, Chase Bank assigned DiNaples’ past-due credit card account to MRS BPO for collection. In attempting to collect DiNaples’ account, MRS sent a collection letter with a QR code printed on the face of the envelope. When scanned, the QR code displayed the MRS account number assigned to...

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