think your honor the morning in may it please the court this is a case about unfair credit reporting by a debt collector the plaintiffs in this case each had one accounts with a creditor which consisted of a series of charges and  single accumulating but the defendant debt collector decided to break up the account into each of its component charges and to credit report each of those component charges as if it was a separate account we were to rule your way in this case wouldn't we have to hold that action would violate section six thousand and ninety two af while at the same time for respecting the misleading statement as to the character of the debt and this court decided that character was a very narrow concept that referred to whether it was secured or unsecured whether the debt consisted of just the underlying obligation or additional attorney fees that were tacked onto that obligation but that whether it was a single account for multiple accounts did not speak to the character of the debt and so what we're left  ongoing relationship between two parties involving accumulating debt and credit and a single balance that reflects those accumulating debt and credit and then that dovetails with the credit reporting issue because a trade line which is sort of an entry about a specific debt in a recent us credit report a trade line as defined by all of the credit bureaus is one trade line for each account and so when the debt collector reported multiple trade lines for all of the component charges it was a misrepresentation about what was actually the relationship between the consumer and the creditor if you don't believe it should be defined  sec it's not defined in the statute so i think my my beliefs about that are largely irrelevant but but what we're talking about here is was the conduct unfair and the way that a court needs to determine whether a con of conduct is unfair or not is to look at what what was actually being done here and what was being done is you're making a consumer who has a single delinquent balance with one creditor you're making the consumer look like they're opening almost all of the reason in that opinion would be simply applicable as well to talk about per transaction reporting and that's what we had here per transaction reporting transactions important because we're when be considered in the credits in the credit score if they want to aggregate it so instead of a two hundred and ten dollars at they have a four hundred dollars debt it makes no sense it's detrimental to consumers likewise with aggregation as is done on a per account basis for example if you accumulate a number of charges from a credit card month to month you do not have a separate trade line that itemize each of those charges or itemizes each of your monthly bill it is all consolidated into a single straight line because you have one account and so that is how credit reporting is done and by transaction per transaction reporting you are creating a fal image of the consumer making it once again look look like they're opening and defaulting on separate accounts all over town this statute of limitations in additional information argument is a red herring there might be benefits to inaccurate credit reporting that accrue to consumers but that does not relieve the obligation of debt collectors to accurately report the information and it does not relieve them of liability when the inaccuracy is that they report reporting a case but that this is not it's simply a fair debt collection practices act case and it's simple and this in the simplicity boils down to is what you said to the credit reporter the credit bureaus a true reflection of your relationship with this consumer and if the answer is no it is not and the way that you did it that was not accurate is harmful then that's where section sixty nine if you have springs in to prevent debt collectors from engaging in this type of harmful unfair and unconscionable credit reporting and then with respect to you know burdens on other industries again there's nothing special about the health care industry when it comes to customer accounts you know just like when i work with a process server and i send them out relationship that is resolved in terms of accumulating all the debts and credit and determining what the final balance is based on a course of conduct between the parties and their regular course of dealing and that's how this stuff works under common law advocating for is an exception for the health care industry where they can report things inaccurately make it look like there are multiple different accounts all for their own benefit because i guess it's simpler to report them on an in by invoice basis as opposed to an account by account basis and once again even if there are some fringe benefits in certain circumstances that accrue to consumers the inaccurate reporting and the unfair nature of th reporting is what this case is about and it overcomes any hypothetical benefit that consumers to the sea and then again with respect to the wrong case the issues there were just completely different  yes that the credit reporting was accurate in so much as the dates of service were accurately reflected the amounts of the invoices were accurately reflected but the inaccuracy is not about the date and it's not about the amount of individual invoices