ten seventy seven madison avenue with you that they were required to have a license that they did not have the license correct so you know what it was the effect of that effect is that they were not in a position or should not be in the positions commence action and action should judgment should be reversed outstanding and when the interest rate if an interest rate applies when it starts from which is one of the issues that was raised by that  i'm just where does it say that someone who is a debt collection agency who should have a license or which should have a license isn't allowed to collect on discoveries that they did not have a license right so the question is whether they fit under the new york city code as a debt collection agency director other and they did well that's your point obviously they don't agree with you and that's why we're here  cousin i want you are saying you know i can handle this business you give me ten thousand bucks here's the mortgage foreclose on it and you can keep the difference street here established standing as the holder of the note your view is that we still have to consider these issues of assignment and consider your attack on the chance at a bricks yes one so even if he i mean if  copy of the note you can't just put in a paper copy and obtain a judgement in a foreclosure they there's literally nothing in this entire action that supports or should give them a judgement that the originals and have attended they were never shown to anyone we have an affidavit which is inconsistent from an employee of ten seventy seven we're not lax to any discovery depose any of the offices and whether you're covered by this provision we're talking about is  all of that works through prior lives that cetera but why why it seems to me the way the world operates one doesn't acquire bad debt unless one intends to turn it around and make some money on it or at least recoup whatever you paid for the is correct to collect on the debt through litigation and then why doesn't that fit into the language that judge parker was i believe it's in section twenty four ninety person to gauge the business the principal person the purpose of which is to me you're covered directly by this line l the language is that a business that that has as its principal purpose it or that regularly collects debt is that your business i think my client's entity was formed for this for the sole purpose of purchasing does that client yes that's for the purpose of purchase is that my client is in the business of owning what the principal purpose of ten seventy seven madison street was was not presented the argument was presented in opposition to summary judgment but there was no evidence that was submitted to establish that my client isn't the principal business  collecting that and and and therefore they fail to raise an issue of fact in response to the summary judgment motion has ten seventy seven madison street board yet in addition to this i have nor did they may have but i have no idea i don't i do know and this is just not part of the record but i do know that as as a matter of business usually when the investors buy that they open an l l c for principal purpose so well not only is it the principal purpose of like that it's the only purpose well it collects like that in this case it it may if you would raise the only the only thing you're relying on is the fact that before th that's the case or you're right but i'm not sure what the outcome of that case was i don't think that i was able i'm not sure of the was an outcome of the time they would be for that or you know setter i'll just add a little fact of the full day that you know the reconsideration without offering any reason or any explosion why it was not submitted in the first instance in opposition to summary judgment and even then there was no affidavit by the defendant with personal knowledge that in fact the default date was not the day that was allegedly the complaint but with a  that was that part of the summary judgment record below you know that and that is his argument is that on this arguably central question there was no evidence that the principle purpose let alone the only purpose of ten seventy seven was to collect that maybe the evidence was that it you know got these different mortgages and signy that i will grant you but where is the evidence that it its principal purpose was to collect it so that that wasn't on summary judgment but the new york city could at the straight code was raised on the summary judgment of the argument was raised but where was the evidence there was no there was no then the court would have had no jurisdiction to hear the case on the action was not commence once july fourteenth two thousand and sixteen which is more than six years past that if all we would have jurisdiction but there would be  but we're not sure what the relief is as a result of it being a crime you can go to jail you can still collect your debt well actually one way to think about it and it actually says bought the debt it was void because they didn't have a license it can't be that if that's what the law says and this well that's what we say too if that's what the law says but what we're trying to do is figure out what the law is you know that they could be that's just seems to me totally illogical that particularly in the state of new york frankly which is sort of the epicenter one of the epicenters in the world of commercial law and they're suddenly  ding tossing out legitimate mortgages and notes because somebody takes a misstep of acquiring it doesn't have a license to do so i think the bank in those very streets every single bank that gives is title to the property subject to d fees and here in new york saline state obviously but you have an ability to get the first bite in on acquiring a piece of property by acquiring a mortgage and if you're quite a mortgage and you're forcing a mortgage you're acting like a bank you're acting like a smart real estate investor is one way of looking at i think new york city so i think increasingly i'm seeing this is a man a really fundamentally of some who just might and your response when i asked you about any evidence  declaration and submit that to the district court to explain that summary judgment was not justified because there was an inadequate opportunity there to reason was not put in a motion