Task: Text Completion
Input (English): sophisticated consumer” might well reach the same conclusion. In sum, particularly at this early stage, defendants cannot establish as a matter of law that Santander is a creditor exempt from the FDCPA. Thus, the motion to dismiss should be denied. TCPA Claims Defendants move to dismiss plaintiffs’ claims under the TCPA based on an exception contained in 47 C.F.R. § 64.1200(a)(2), which excepts calls to a residential line when made pursuant to an “established business relationship.” It is difficult to imagine how that exemption would apply to Letricia Hamlett, who was not a signatory to the loan, but in fairness there is at least one case that supports this odd interpretation of the law. See Santino v. NCO Fin. Sys., Inc., No. 09-CV-982, 2011 WL 754874, at *6 (W.D.N.Y. Feb. 24, 2011) (<HOLDING>); but see Watson v. NCO Group, Inc., 462 
 Holding statements: (A) holding  2254 applies to administrative proceedings (B) holding that the fourteenth amendment only applies to state action (C) holding exemption applies to nondebtor (D) holding that fourteenth amendment only applies to state action (E) holding that  1447c applies to counsel
Output (English): (C)