Camacho

BACKGROUND

Camacho’s debt of $42.57 was assigned to Bridgeport Financial by Into Video.1 In its initial collection communica- tion, Bridgeport Financial included the statement: “Unless you notify this office in writing within 30 days after receiving this notice that you dispute the validity of this debt or any por- tion thereof, this office will assume this debt is valid.” (Emphasis added.) Camacho sued under §§ 1692g and 1692e of the FDCPA, alleging that this statement misrepresented the rights of consumers because it required Camacho to dispute the debt in writing. Bridgeport Financial filed a motion to dis- miss the action under Federal Rule of Civil Procedure 12(b)(6), arguing that § 1692g(a)(3) implicitly requires dis- putes to be in writing because only written disputes can invoke the other protections afforded by the FDCPA. The dis- trict court rejected Bridgeport Financial’s arguments, holding that the plain meaning of § 1692g(a)(3) did not require that 1 This case was brought as a putative class action, but the district court has not yet ruled on the class aspects of the case. CAMACHO v. BRIDGEPORT FINANCIAL INC. 16235 disputes be in writing and that this…