Robert Renick, on Behalf of Himself and All Others Similarly Situated v. Dun & Bradstreet Receivable Management Services

Renick didn’t pay his phone bill. After his account became seriously past due, Dun & Bradstreet, the phone company’s collection agent, sent Renick a collection notice. As required by the Federal Debt Collection Practices Act (“FDCPA”), 15 U.S.C. § 1692g(a), the notice informed Renick that he had the right to dispute the validity of the debt within 30 days, and that Dun & Bradstreet would then provide him with verification of the debt.

Twenty days later, Dun & Bradstreet sent a second notice. On the front, it asked Renick to “[u]se the tear-off portion of this letter ... to send your payment today.” The reverse side provided the validation information required by the FDCPA, and stated that “PROMPT PAYMENT IS REQUESTED.” The notice also told Renick to contact the telephone company with any questions about his phone account, but to direct all inquiries regarding the validity of the debt to Dun & Bradstreet.

Renick sued, alleging that the second notice violated the FDCPA. He argued that, coming only 20 days after the first collection notice, the request for “prompt” payment and payment “today” misled him into abandoning his statutory right to contest the validity of the…