Third Circuit: Debt Collector’s “True Name” FDCPA Violation Did Not Violate Other FDCPA Provisions

The U.S. Court of Appeals for the Third Circuit has ruled that although the plaintiffs had plausibly alleged facts stating a claim that a debt collector had violated the Fair Debt Collection Practices Act (FDCPA) by not using its “true name” in prerecorded phone messages, the plaintiffs failed to state claims for violations of the FDCPA provisions that prohibit collectors from placing phone calls without “meaningful disclosure of the caller’s identity” or using false or deceptive means to collect a debt or obtain information concerning a consumer. The decision illustrates the value of careful analysis of FDCPA claims in defeating attempts by plaintiffs’ attorneys to “piggy back” such claims.