Chai

I. BACKGROUND

We take our factual summary from Chai’s complaint, accepting as true all well-pleaded material facts. (See Dunn v. County of Santa Barbara (2006) 135 Cal.App.4th 1281, 1298 (Dunn); see also Yvanova v. New Century Mortgage Corp. (2016) 62 Cal.4th 919, 924.) Velocity, a debt buyer, purchased consumer debt incurred by Chai that original creditor Citibank, N.A. had “charged off” as a loss.2 Velocity through its agent sent Chai a written communication about the debt but omitted the required notice of Chai’s right to request records. Suing for violation of the statute in his individual capacity and as representative of a putative class, Chai sought statutory damages under section 1788.62, subdivision (a)(2) but disclaimed any “concrete injury” from Velocity’s violation of the Act. Alleging that Velocity’s defective letter represented its standard practice, Chai sought as class relief an award of additional damages under section 1788.62, subdivision (b). The trial court certified a class of persons with California addresses to whom Velocity’s agent had sent

2 Chai generally denies in his complaint any debt to the original creditor but bases his claims on Velocity’s…