congressional mandates are not immaterial neither are violations of congressional mandates and the debt collectors false affidavits in this case openly defy congressional mandates under the fair debt collection practices act just like sewer service affidavits openly defy due process and just like false affidavit two items number one are informational injuries that congress sought to protect under the act specifically true truthful information which but it has t informational injuries based on untruthful information and standing actual damages in the trial court attorney's fees and costs defending the case she said in her affidavits how did that affect her in the living a how did that how did that affect and sophisticated consumer and their relations with their creditors well number one it interferes with their ability to determine potential defenses you know such things a standing trustworthiness of evidence and the amount of based on truthfulness in the affidavits on probative and material issues of standing trustworthiness and the admissibility of evidence in addition to actual damages of attorneys fees and costs to uncover these things sufficient to give rise to article three standing distinguishing that here i would say that congress didn't seek to protect incorrect zip code it did seek to the this case count because you could say that false statements for an issue and spokeo to but then there was one particular falsity that was identified that wouldn't be enough and so the question would be saying you can't do it or that you haven't done it i'm just asking for your assessment of what the difference would be here i think these are congressionally protected rights of ms frank on she gave the wrong st name would you have a claim for that associate that certainly could influence an unsophisticated consumers decision whether to contest or concede the suit if she doesn't well and again i'm just thinking of this case  t hypothetically if they if the consumer has never done business with this debt collector they may not know if they even owes them a debt at all let alone the amount th collector is claiming because you can't hide that specific individual to a particular debt collector at least the one suing her to think it would be actionable if you said how it's done rather than christine do couple a couple of items you mentioned you mentioned attorney fees and costs here but as i read her deposition frank said none of the attorney well she she did testify she was confused as to why she would be responsible for attorney's fees so that certainly is tied to any council which is another reason why she heard all king good morning your honor smith please the court my name is scott king i represent the apple e's auto vest and michael interesting associates the athletes asked the court to a from the strength legal arguments suffer from a happen the balance due on this contract with one dollar to three hundred and sixty five dollars auto best lawyer in the can elections action flag that he had a twenty percent contingency fee twenty percent of nine thousand  three hundred and sixty five dollars is one thousand eight hundred and seventy three dollars but in the collections action on a best of nazi attorney fees of eight one hundred and seventy three dollars it only sought attorney fees one hundred and ninety would read all the other sentences around there and say which one are they thinking in this case and i wouldn't see it anywhere that seems awfully confusing  boxes right i'm not i'm not saying there's no doubt that that's the total of all those numbers up on top of that being your math i'm just saying i'm got two boxes here and i'm just asking whether you're unsophisticated which is why when the other one would be in the that's what specifies the number and i'm not seeing where that i don't believe it is in the r  with your friend about the standing question what we do have to think that through there is absolutely no actual injury with respect to miss frank testified that the items that are issue in this case didn't matter to her she testified that she neither took action nor failed to take action with respect to those items s requires actual injury to the plaintiff before the court i agree with the analysis that spokeo bars this client because false statement but it was faulty i believe the answer to that question again it's not in the record but i believe that the answer that question is that the attorney for this case prepared the affidavit and mr doonan should have corrected it before he signed it but he didn't and that was that's a mistake that gives rise to the client's thank any false statement no matter how trivial would give rise to a violation and that's simply not the case under article three there has to be actual concrete injury tied to the violation and in this case there is no such injury on the record the employment hearing that has been advocated on this record  which is her deposition testimony lines twelve through fift millette you pointed out one page says one thing another page says another and then unsophisticated consumer know just like ms frank wouldn't know what she's supposed to pay or why she's even having to pay it and i will point out that the unsophisticated consumer is below average intelligence and sophistication i think another important point is that the appellant never had a right contractually or legally to recover fees in the st place with respect to spokeo miss franks suffered a concrete injury because the injuries the informational injuries in particular that she suffered are protected by congress which therefore require no additional proof of harm unless the court has any other questions we would ask that the course reverse and re