please the court your honor the letters here do not actually identify chase as the creditor or to borrow from genet they simply do not say who currently own the debts so certainly it's permissible to leave the identification of the current creditor to being implied but the  standard for doing that is whether under that specific consumer standard whether it's a basic logical deduction so the question then becomes is does this letter allow consumer to make a basic logical deduction that chase is the current creditor you think it's good enough of a use implicit to the creditors what what what i'm saying is i think that jeanette else is very clear that has to be clearly dispute the cases that for example that might say yes we've been you know we are collecting on behalf of the above referenced creditor or the above reference client i think that probably is dollars hired us to from to collect it exactly which is what which is we were saying is the fault here that this you know and i apologize but obviously that the prior argument dealt with similar issues but and we wouldn't be here today it wouldn't be a claim so we think that obviously there's a bunch of unreported district court cases from the country that both sides  cited but we think that the ones that client services rely upon the reasoning in those in those decisions are reasons that were expressly rejected and in janet house and specifically one is that they say is that the letter clearly identifies client services as the debt collector and then the argument that they make is by process elimination then the only other entity name must be the current letter identifies a client services as a debt collector does not mean that the that the only the other entity named in the letter must be the current creditor i think that's true but i think that the sentence account has been placed with our organization for collections i think the question here is whether that reference to the above account chase bank account number permits the logical inference that that's the creditor at one time on the debt in the past the reference to just it being an account does not mean that chase is currently that creditor mia and here in particular which is i think facts that are unique to all the other cases is that we have evidence as to that each of these accounts these were not recently like in the case of some medical debt sometimes where it's recent patient is is the debtor they went to the hospital so they would know these were cases where you know in excess of two years two and a half years three more than three years before was the last time that any payment was made to chase and i think that certainly it's fair to to recognize that when the large credit card issuing banks have had debts that are that old that they frequently do get sold to an as cheaper you know skew but i'm worried a little bit here about the language like placing accounts answer i don't know enough and i think they have it really really distinct meanings to the average consumer i don't think that they have a point there they're confusing i think it's you know they've been terms you know an account is assigned as it's a sign for collection what's the purpose of the assignment i mean certainly glee we understand an assignment as a transfer of right i'm trying to put i'm trying to picture my own understanding let's say the st day of law school where i would have struggled with some of those distinctions in even now when i read the verbs place to sign a transfer i'm not sure which of the different meanings they might have david did you will actually seek a firm in italy relief under rule fifty six d with time to respond to the only expected affidavit from the  and please the court xerxes martin on behalf of client services incorporated we're focusing today on one thousand six hundred and ninety two g eighty two which simply requires the name of the creditor to him the day it is that is the case law does not prescribe any particular method in doing that and looking at this case the letter at hand this letter sufficiently does that opposing counsel wants this court focus on its prior precedent of geneticists but that case is not affable in this case because it deals with different facts purchase of a debt and frankly in my opinion a confusing letter the letter in jeanette is stated re asset acceptance l l c assignee of america star they contain original creditor account number  thousand dollars the letter could have been drafted differently this is how it was drafted sometimes the creditor steps chase bank wants letters in a certain style there may be some tension as i client's job to push back if it's not going to clearly comply with the act it can be there is a client relationship that parties want to maintain in that sense maybe this is not a very compelling argument for a firm dismiss case this case let me ask you the same question is there the verbs placed in a signed and transferred st in the in the debt collection industry only ambiguous clearly distinguished in the way you're used i don't believe they are clearly distinguished by case law or by any means i mean a business well in how about with with consumer debtors they're left to their own interpretation is that the only way to interpret that you're familiar with the john oliver story probably from last year or so about the selling of zombie debts and so on correct already here in that hardest kind of money yeah the phone formed a collection i reach that interpretation given the way this industry operates course that have looked at this identical letter and others very similar to this letter have said that because this letter only states the name of the creditor and then the name of the debt collector a balance and then the origination date and this court held that that letter properly conveyed to the current creditor was and frankly i believe that that letter is actually more confusing than this one because that particular letter state also i mean it does go back to your differences of placed a sign transferred to my interpretation of place would be this account has been placed them for collection as the letter says and on a temporary basis i think transfer  least possibly in for a legal sense that the rights to the debt have been transferred in your brief you wrote unlike the words assignee and transferred in geneva the word place to does not suggest any change in ownership i read and i said really mean how do i know that i'm not sure i know that as somebody with some experience in the federal courts i have no idea how i'm supposed to figure that out as a consumer who maybe just finished th grade i think in normal english language i mean would you say you place something with a friend when it's actually a gift or did you transfer that to a friend as a gift i don't think many people you know that when you went into law school i have not seen a place necessarily in a contract or otherwise using placed as a transfer of rights and or ship or otherwise i would like to steer this court to the case of campo versus clients or incorporated it is an opinion that came out on a summary judgment motion in the eastern district of new york which is the identical letter we're dealing with  bank walmart and see right below this line letter identify the account number and balance to which especially in conjunction with the name of the creditor is sufficient and from asian for the even the least sophisticated consumer to understand that the debt collection letter is attempting to collect a debt for her account history and so putting that together the consumer knowing their account history and knowing their financial history receiving a letter sent by client services in this case now that they had a chase bank account the account had been placed with client say it the letter silent as to anyone else that could possibly be owed to silence and so based on that it can be inferred that the only two people mentioned in the letter chase bank and cli my position is that is the only inference because those are the only two parties mentioned in the letter and what do we make we talked about pay you rather pay your client rather than creditors address it's the collection agencies and then doesn't that notice which is required by the statute kind of help imply that well maybe these are different that's kind of a question for congress because that is what they drafted to be included in every   you know just kogan did rely upon that but there are a couple things in involved in that case that are different here which is there's no indication about how old the debt was  that had been paid over three years but in janet toast you talked about that again you know apply genitals here the consumer may recognize they that chase currently that if anything the court just you know the consumer would just be making a guess as to whether they were still that way but i mean if they were still the current creditor there is still the credit to him that that was owed and the other factor is again to be in the letter so to say oh well if it's if it's not the debt collector than the other name there must be the current creditor is is is in this is based upon an assumption that there's no basis for making that assumption and that's  failing of the number of cases that client services cited from the other districts which are outside of the circuit and and i think i i don't want to belabor it counsel did make reference to that smith versus s