D.N.J.: If Relationship Between Collector and Creditor is Clear, Including Chain of Title Does not Make Creditor Identification Unclear

Debt collectors are no strangers to Fair Debt Collection Practices Act (FDCPA) claims regarding how creditors are identified in debt collection letters. Each court decision that comes out on the issue provides some clarity. The District of New Jersey (D.N.J.) provided some of this clarity in Gross v. Lyons, Doughty & Veldhuis, P.C., No. 18-cv-7963 (D.N.J. Dec. 3, 2018), where it granted dismissal of a claim alleging that including chain of title makes a letter unclear.

Factual and Procedural Background

Lyons, Doughty & Veldhuis, P.C. (LDV) send a collection letter to plaintiff that included the following caption:

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