Camacho

I. Facts and Proceedings Below

In the underlying action, Camacho, a debtor, sued Bridge- port Financial, Inc. (Bridgeport Financial), a debt collector, in CAMACHO v. BRIDGEPORT FINANCIAL 4243 a putative class action alleging violations of the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. §§ 1692g, 1692e. Camacho alleged that Bridgeport Financial misrepre- sented the rights of consumers in its initial collection letter by requiring her to dispute her debt in writing. Bridgeport Finan- cial filed a motion to dismiss, arguing that section 1692g(a)(3) implicitly requires disputes to be made in writing. The district court denied Bridgeport Financial’s motion to dismiss, certi- fied the issue for interlocutory appeal, and we affirmed in a published opinion. See 430 F.3d 1078, 1082-83 (9th Cir. 2005). We held that the district court correctly denied Bridge- port Financial’s motion to dismiss because there is no writing requirement implicit in section 1692g(a)(3), and that Bridge- port Financial violated that section insofar as it stated that dis- putes must be made in writing. Id. at 1082.

On remand, the litigation focused on class certification, Bridgeport…