Douglass v. Convergent Outsourcing, No. 13-3588 (3d Cir. 2014)
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Douglass received a letter from Convergent regarding a debt that Douglass allegedly owed T-Mobile. Convergent used an envelope with a glassine window, through which were visible: Douglass’s name and address; a sequence of numbers representing Douglass’s account number with Convergent that does not refer or relate to her T-Mobile account; a Postal Service bar code; a QR code, which, when scanned by a smart phone, revealed the same information as displayed through the glassine window; and a monetary amount corresponding to Douglass’s alleged debt. A putative class action on behalf of recipients of similar letters alleged that disclosure of the account number on the envelope and embedded in the QR code, violated the Fair Debt Collection Practices Act, 15 U.S.C. 1692f(8), which prohibits “using any language or symbol” other than a debt collector’s name and address on an envelope. Convergent argued that the account number qualified as “benign language.” The district court granted summary judgment to Convergent, reasoning that a strict interpretation of section1692f(8) would contradict Congress’s true intent: barring markings that would reveal the letter to pertain to debt collection or harass or humiliate a consumer. The Third Circuit vacated, stating that the account number could identify Douglass as a debtor and its disclosure was not benign.
The court issued a subsequent related opinion or order on October 10, 2014.
The court issued a subsequent related opinion or order on October 10, 2014.
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