Nabozny v. Optio Solutions LLC, No. 22-1202 (7th Cir. 2023)
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Nabozny received a letter at her Wisconsin home, offering to settle an unpaid credit-card debt. The letter summarized basic information about her debt: the creditor, the outstanding balance, the account number, and her name and address. The letter was from Optio under its operating name of Qualia, but it was printed and mailed by RevSpring, a third-party printing and mail vendor. Nabozny did not give Optio consent to share the information about her debt with RevSpring.
Nabozny filed a purported class action, alleging that Optio’s communication with RevSpring violated the Fair Debt Collection Practices Act, 15 U.S.C. 1692, which provides that “a debt collector may not communicate, in connection with the collection of any debt, with any person other than the consumer” without the consumer’s consent. The Seventh Circuit affirmed the dismissal of Nabozny’s suit for lack of subject-matter jurisdiction. Nabozny lacks standing to sue because she “suffered no concrete injury.” The court noted recent decisions in other circuits that sharing a debtor’s data with a third-party mail vendor to populate and send a form collection letter “causes no harm that our legal tradition recognizes as sufficient to support a suit in federal court under Article III of the Constitution.”
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