Caprio v. Healthcare Revenue Recovery Grp., LLC, No. 12-1846 (3d Cir. 2013)
Annotate this CaseHRRG is in the business of acquiring or collecting debts under the FDCPAs definition of a “debt collector,” 15 U.S.C. 1692a(6), and sent Caprio a double-sided “Collection Letter.” Caprio filed a putative class action, alleging two claims under the Fair Debt Collection Practices Act, claiming that the letter’s instructions would confuse “the least sophisticated consumer” about how to dispute the alleged debt. The district court granted Caprio judgment on the pleadings. The Third Circuit vacated and remanded, concluding that the collection letter was deceptive because it can be reasonably read to have two or more different meanings, one of which is inaccurate.
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