QR Codes Mean FDCPA Trouble Says PA Federal Court

A QR code visible on the face of an envelope embedded with an account number violates the Fair Debt Collection Practices Act, according to a recent decision from the United States District Court for the Middle District of Pennsylvania.

A QR or “Quick Response” code is a type of bar code that can contain any sort of information. But the information is not visible, instead the QR code looks more like a jumble of black and white lines or boxes. You can’t do much with a QR code unless you have a device that can read the code.

In Styer v Professional Medical Management, Inc., the court granted summary judgment to the plaintiff, finding that a QR code on an envelope that when read using a decoder would reveal the debtor’s name, address and account number, violates § 1692f(8) of the FDCPA because it exposed to the public information about Styer’s “financial predicament.” Section 1692f(8) prohibits a debt collector from using “any language or symbol, other than the debt collector’s address” and its business name, “if such name does not indicate that he is in the debt collection business.”

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