Dinaples v. MRS BPO LLC, No. 18-2972 (3d Cir. 2019)
Annotate this CaseDiNaples fell behind on her Chase credit card payments. Chase assigned her account to MRS, a debt collection agency, which sent DiNaples a collection letter as a pressure sealed envelope that had a QR code printed on its face. The QR code can be scanned by a reader downloadable as a smartphone application to reveal the internal reference number associated with DiNaples’s account at MRS. DiNaples filed a class action lawsuit under the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. 1692–1692, which prohibits debt collectors from “[u]sing any language or symbol, other than the debt collector’s address, on any envelope when communicating with a consumer by use of the mails.” The Third Circuit affirmed summary judgment that MRS violated the FDCPA. A debt collector violates section 1692f(8) by placing on an envelope the consumer’s account number with the debt collector. There is no meaningful difference between displaying the account number itself and displaying a QR code — scannable “by any teenager with a smartphone app” — with the number embedded. The court rejected MRS’s contention that DiNaples had not “suffered a concrete injury,” explaining that DiNaples was injured by “the disclosure of confidential information,” and rejected MRS’s assertion of the FDCPA’s “bona fide error defense.”
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.