facts in the light most favorable to Burgess, she has evidence of a single call in

connection with a debt, placed roughly two years after she told Defendants she

1 Because we conclude that summary judgment was proper on both claims Burgess pursues on appeal, we need not address PRA Group’s alternative argument that it is not a “debt collector” subject to liability under the FDCPA. 2 could not pay. She cites no authority suggesting that such a call is unlawful under

§ 1692d.

2. We also affirm summary judgment on Burgess’s claim for a violation

of the FDCPA’s ban on false or misleading representations. 15 U.S.C. § 1692e.

Applying the “least sophisticated debtor” standard, we conclude that the dunning

letter Burgess received was not unlawfully misleading for four reasons. See Davis

v. Hollins Law, 832 F.3d 962, 964 (9th Cir. 2016). First, the dunning letter did not

contain implied threats of litigation or an indication that the debt was legally

enforceable. The letter Burgess received adequately disclosed that the debt was

time-barred. Second, the letter’s offer to pay the debt at a discount was not illusory

because Burgess may have been able to benefit by eliminating a delinquent account

from her credit report. Third, Burgess cites nothing to suggest that enrolling in

LifeCents revives the statute of limitations in whole or part. Finally, the “least

sophisticated debtor” is presumed to read documents with care, Davis, 832 F.3d at

964, so we reject Burgess’s attempt to fault Defendants for the fact that she tore the

dunning letter inadvertently.

AFFIRMED.

3