PRECEDENTIAL

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT

_____________

No. 17-3330

_____________

ELAINE LEVINS; 

WILLIAM LEVINS, on behalf of themselves 

and others similarly situated,

 Appellants

v.

HEALTHCARE REVENUE RECOVERY GROUP LLC, 

a/k/a ARS Account Resolution Services;

JOHN AND JANE DOES 1 THROUGH 25 

_____________

On Appeal from the United States District Court

for the District of New Jersey

(D.C. No. 1-17-cv-00928)

District Judge: Honorable Robert B. Kugler

_______________

Argued

June 5, 2018

Before: AMBRO, JORDAN, and VANASKIE, Circuit 

Judges
2

(Filed: August 22, 2018)

Daniel A. Frischberg

525 Route 73 South

Evesham Commons

Marlton, NJ 08053

Philip D. Stern [ARGUED]

Andrew T. Thomasson

Stern Thomasson

150 Morris Avenue, 2nd Floor

Springfield, NJ 07081

 

 Counsel for Appellants

Sean X. Kelly

Christian M. Scheuerman [ARGUED]

Marks O’Neill O’Brien Doherty & Kelly

535 Route 38 East, Suite 501

Cherry Hill, NJ 08002

 

 Counsel for Appellee

_______________

OPINION

_______________

JORDAN, Circuit Judge.

In this appeal, we interpret three provisions of the Fair 

Debt Collection Practices Act (“FDCPA”), 15 U.S.C. §§ 1692-

1692p. Elaine and William Levins allege that Healthcare 
3

Revenue Recovery Group LLC (“HRRG”) violated 

§§ 1692e(14), 1692d(6), and 1692e(10) by leaving telephone 

voice messages that did not use its true name, did not 

meaningfully disclose its identity, and used false 

representations and deceptive means to collect or attempt to 

collect a debt or obtain information about a consumer. In 

particular, the Levinses complain that voicemail messages in 

which HRRG went by the name of “ARS” were insufficient to 

identify it as HRRG or even as “ARS ACCOUNT 

RESOLUTION SERVICES,” which is an alternative business 

name used by HRRG. HRRG moved to dismiss the complaint, 

as amended, for failure to state a claim, and the District Court 

granted that motion.

We conclude that the Levinses have stated a plausible 

claim that HRRG violated § 1692e(14)’s “true name” 

provision, but they have not stated plausible claims under 

§§ 1692d(6) or 1692e(10). Accordingly, we will vacate in part

and affirm in part the dismissal of their case.

I. BACKGROUND

A. Allegations In The Complaint1

The Levinses, who live in New Jersey, purportedly

incurred a debt that was transferred to HRRG for collection. 

HRRG then began leaving pre-recorded voicemail messages 

 

1 For convenience, we refer to the amended complaint 

simply as “the complaint.” We construe the allegations of that 

pleading in the light most favorable to the Levinses. See infra

note 2.
4

on the Levinses’ phone in an attempt to collect the debt. The 

following is a transcription of the message:

ARS calling. Please return our call at 1-800-694-

3048. ARS is a debt collector. This is an attempt 

to collect a debt. Any information obtained will 

be used for that purpose. Again, our number is 

1-800-694-3048. Visit us at 

www.arspayment.com.

(App. at 22 ¶ 31.)

At the time the Levinses received that message over and 

over, they did not know the identity of the caller. They had

never received any written communication from HRRG. 

Having recently gone through bankruptcy, they knew of a debt 

collector with the full name “ARS National Services, Inc.” that 

was known as “ARS” for short. That company, however, turns 

out to be wholly unrelated to HRRG. While it has registered 

the name “ARS ACCOUNT RESOLUTION SERVICES” in 

New Jersey, HRRG has neither registered the stand-alone 

name “ARS” nor taken any other legal steps to do business 

under that specific name. 

There are numerous businesses that use the name 

“ARS,” including the debt collector the Levinses had heard of,

which is a California corporation registered to transact

business in New Jersey. According to the Levinses, “by 

reputation the name ‘ARS’ is, without more, associated in the 

nation’s debt collection industry with ARS National Services 

Inc.” (App. at 23 ¶ 41.) A Google search of “ARS” along with 

“debt” or “collector” will result in links to many debt collectors 

other than HRRG. Reference to www.arspayment.com, the 

website that HRRG mentioned in the pre-recorded messages it 
5

left for the Levinses, does not narrow the field. It only leads to 

a browser privacy warning that blocks access to the website. 

And, if one ignores the warning and accesses the site, the 

website begins tracking and storing information about the

computer user. 

B. Procedural History

Within a year of receiving the voicemail messages from 

HRRG, the Levinses filed their putative class-action complaint 

alleging that HRRG violated the FDCPA when attempting to 

collect debts from them and others similarly situated. They

eventually filed an amended complaint in which they claimed

that the pre-recorded messages violate 15 U.S.C. 

§§ 1692e(14), 1692d(6), and 1692e(10) because they “use the 

name of any business, company or organization other than the 

true name of the debt collector’s business, company, or 

organization”; “fail to provide meaningful disclosure of 

HRRG’s identity”; and “use false representations and 

deceptive means to collect or attempt to collect any debt and to 

obtain information concerning a consumer[.]” (App. at 19 

¶ 13.)

HRRG moved to dismiss the case, invoking Federal 

Rule of Civil Procedure 12(b)(6). Along with its motion, 

HRRG filed an attorney declaration with supporting 

documents. Among those was a certificate stating that it is 

registered to do business in New Jersey under the name “ARS 

ACCOUNT RESOLUTION SERVICES,” and a collection 

letter that it purports to have sent to Elaine Levins in November 

2015. The Levinses opposed HRRG’s motion and submitted 

their own attorney declaration with documents listing hundreds 

of businesses registered in New Jersey under names that 
6

include “ARS.” After reviewing the parties’ submissions, the 

District Court granted the motion to dismiss. 

The Levinses have timely appealed. 

II. DISCUSSION2

In appealing the order dismissing their complaint for 

failure to state a claim, the Levinses make three arguments. 

First, they say that HRRG violated § 1692e(14) because it did 

not use its true name in the voicemail messages. Next, they

argue that HRRG violated § 1692d(6) because the messages 

did not meaningfully disclose the caller’s identity. And finally, 

they assert that HRRG violated § 1692e(10) because forcing 

consumers to call HRRG or navigate its website is a deceptive 

 

2 The District Court had jurisdiction under 28 U.S.C. 

§ 1331. We have jurisdiction pursuant to 28 U.S.C. § 1291. 

“We exercise plenary review over a district court’s dismissal 

for failure to state a claim under Rule 12(b)(6), applying the 

same standard as the district court.” Glover v. FDIC, 698 F.3d 

139, 144 (3d Cir. 2012). “We will affirm an order dismissing 

a complaint only when the complaint fails to contain sufficient 

factual matter, accepted as true, to state a claim to relief that is 

plausible on its face.” Rotkiske v. Klemm, 890 F.3d 422, 424

n.2 (3d Cir. 2018) (en banc) (internal quotation marks omitted). 

“A claim has facial plausibility when the plaintiff pleads 

factual content that allows the court to draw the reasonable 

inference that the defendant is liable for the misconduct 

alleged.” Tatis v. Allied Interstate, LLC, 882 F.3d 422, 426 (3d 

Cir. 2018). We construe the allegations in the complaint in the 

light most favorable to the non-moving parties, the plaintiffs. 

Id.
7

means to collect debts and obtain information about a 

consumer. 

HRRG of course disputes all of those contentions. It 

says that it did not violate § 1692e(14) because “ARS” is an 

abbreviation of its registered alternative business name “ARS 

Account Resolution Services,” which is a true name. It then 

contends that it did not violate § 1692d(6) because the

messages said that the caller was a debt collector, pointed out

that the purpose of the call was to collect a debt, and provided 

a phone number and website for the consumer to use, all of 

which was a sufficient disclosure of identity. And, last, it 

argues that it did not use deceptive collection practices in 

violation of § 1692e(10) because the messages informed 

consumers that any information obtained would be used to 

collect a debt. 

Before turning to the parties’ competing arguments, 

though, we must determine which materials can properly be 

considered in evaluating the District Court’s decision to

dismiss the claims under Rule 12(b)(6).

A. We Decline To Rely On The Collection Letter 

Attached To HRRG’s Motion To Dismiss 

Because The Complaint Does Not Reference 

Or Rely On It.

We “generally consider only the allegations contained 

in the complaint, exhibits attached to the complaint[,] and 

matters of public record” when evaluating whether dismissal 

under Rule 12(b)(6) was proper. Pension Benefit Guar. Corp. 

v. White Consol. Indus., Inc., 998 F.2d 1192, 1196 (3d Cir. 

1993). But we can also consider “an undisputedly authentic 
8

document that a defendant attaches as an exhibit to a motion to 

dismiss if the plaintiff’s claims are based on the document.” 

Id. We may do so because “the primary problem raised by 

looking to documents outside the complaint—lack of notice to 

the plaintiff—is dissipated where the plaintiff has actual 

notice ... and has relied upon [those] documents in framing the 

complaint.” Schmidt v. Skolas, 770 F.3d 241, 249 (3d Cir. 

2014) (internal quotation marks, alteration, and citation 

omitted). 

Here, HRRG asks us to consider the collection letter that 

it claims to have mailed to the Levinses in November 2015. 

The letter bears a company logo consisting of the letters 

“ARS,” says in the letterhead that “Account Resolution 

Services” is “a division of HRRG, LLC,” and, in the body of 

the letter, uses “ARS” as an abbreviated name. (App. at 38.) 

HRRG urges us to conclude that the Levinses received that

collection letter before the phone messages and so would have

understood ARS and HRRG to be one and the same. The 

Levinses respond that the letter is off limits at this stage of the 

litigation, and they are right. We will not consider it because 

the claims in the Levinses’ complaint are not based on it. 

Rather, the claims are based on the pre-recorded phone 

messages that the Levinses allegedly received. Indeed, the

Levinses specifically allege that they have never received any 

written communication from HRRG, and we must take that as 

true, see Tatis v. Allied Interstate, LLC, 882 F.3d 422, 426 (3d 

Cir. 2018) (construing allegations in the complaint in the light 

most favorable to the non-moving party).

3

 

3 The District Court’s decision likewise did not 

reference that collection letter. We will, however, consider the 

certificate stating that HRRG is registered to do business in 
9

Of course, our decision not to consider the letter at this 

stage does not mean that it is irrelevant or forever precluded 

from consideration. Assuming it is properly tendered to the 

District Court, HRRG may rely on it later in a motion for

summary judgment or at trial.

With that decided, we can now consider whether the 

Levinses have stated their FDCPA claims with sufficient 

plausibility to withstand the motion to dismiss.

B. The Levinses Have Stated A Plausible Claim 

Under § 1692e(14).

Congress enacted the FDCPA “to eliminate abusive 

debt collection practices by debt collectors[.]” 15 U.S.C.

§ 1692. Because it is a remedial statute, “we construe its 

language broadly, so as to effect its purpose.” Tatis, 882 F.3d

at 427 (internal quotation marks and citation omitted). In 

evaluating whether a particular debt-collection practice 

violates the Act, “we employ a ‘least sophisticated debtor’ 

standard[.]” Id. (citation omitted). “The standard is objective, 

meaning that the specific plaintiff need not prove that she was 

actually confused or misled, only that the objective least 

sophisticated debtor would be.” Id. (internal quotation marks, 

emphasis, and citation omitted). “[That] standard aims to 

 

New Jersey under the name “ARS ACCOUNT RESOLUTION 

SERVICES,” (App. at 35), because it is a matter of public 

record, Pension Benefit Guar. Corp., 998 F.2d at 1196. The 

District Court referenced the certificate in its decision, and 

neither party disputes that choice on appeal. That is the limit 

of what we are considering outside of the complaint.
10

protect the gullible as well as the shrewd, but it nevertheless 

preserves a quotient of reasonableness[.]” Id. (internal 

quotation marks, alterations, and citations omitted).

To state a claim under the FDCPA, a plaintiff must 

allege that “(1) she is a consumer, (2) the defendant is a debt 

collector, (3) the defendant’s challenged practice involves an 

attempt to collect a ‘debt’ as the Act defines it, and (4) the 

defendant has violated a provision of the FDCPA in attempting 

to collect the debt.” Id. Here, the parties only dispute the 

fourth element, i.e., whether the messages violated 

§§ 1692e(14), 1692d(6), or 1692e(10) of the Act. 

We conclude that the Levinses have stated a plausible

claim under § 1692e(14) because, as alleged in the complaint,

“ARS” is neither HRRG’s full business name, the name under 

which it usually transacts business, nor a commonly used 

acronym of its registered name “ARS ACCOUNT 

RESOLUTION SERVICES.” Section 1692e prohibits a debt 

collector from “us[ing] any false, deceptive, or misleading 

representation or means in connection with the collection of 

any debt.” 15 U.S.C. § 1692e. It contains a non-exhaustive 

list of prohibited conduct, one sort of which is “[t]he use of any 

business, company, or organization name other than the true 

name of the debt collector’s business, company, or 

organization.” Id. § 1692e(14).

The FDCPA is enforced by the Federal Trade 

Commission (“FTC”), which has offered guidance on how to 

interpret that statute. Hawthorne v. Mac Adjustment, Inc., 140 

F.3d 1367, 1372 n.2 (11th Cir. 1998). Although the FTC’s 

guidance “does not have the force of law and is not entitled to 

deference in FDCPA cases[,]” we may adopt its interpretation 
11

when we find its logic persuasive. Brown v. Card Serv. Ctr., 

464 F.3d 450, 455 (3d Cir. 2006) (internal quotation marks, 

alterations, and citation omitted). The FTC has interpreted the

“true name” requirement in § 1692e(14) to permit a debt 

collector to “use its full business name, the name under which 

it usually transacts business, or a commonly-used acronym[,]” 

as long as “it consistently uses the same name when dealing 

with a particular consumer.” Statements of General Policy or 

Interpretation Staff Commentary On the Fair Debt Collection 

Practices Act, 53 Fed. Reg. 50097, 50107 (Dec. 13, 1988)

[hereinafter FTC Commentary]. That is a sound interpretation 

of the statutory requirement, and we adopt it as our own.

Here, at this early stage in the case, when we must take 

the allegations in the complaint as true, the Levinses have 

plausibly alleged facts suggesting that “ARS” is not the “true 

name” of HRRG. While they do not deny that “ARS” is a name 

HRRG may use, they say that the acronym is commonly 

associated with other debt collection companies, including 

“ARS National Services, Inc.,” and that it could refer to

hundreds of other businesses registered to do business in New 

Jersey under names that include “ARS.” (App. at 23 ¶¶ 37, 41; 

App. at 41.) See also Sayles v. Advanced Recovery Sys., Inc., 

865 F.3d 246, 248 (5th Cir. 2017) (abbreviating defendant 

“Advanced Recovery Systems, Inc.” as “ARS”); Koby v. ARS 

Nat’l Servs., Inc., 846 F.3d 1071, 1074 (9th Cir. 2017) 

(abbreviating defendant “ARS National Services, Inc.” as 

“ARS”). Nothing in the information properly before us 

indicates that “ARS” is HRRG’s full business name, the name 

under which it usually transacts business, or its commonly used 

acronym. To the extent HRRG argues to the contrary, it is 

doing so without proper record support. It will have an 

opportunity later to expand the record, but for now taking the 
12

allegations in the complaint as true, we conclude that the 

Levinses have stated a plausible claim for relief under 

§ 1692e(14).4

C. The Levinses Have Not Stated A Plausible 

Claim Under § 1692d(6).

Section 1692d prohibits a debt collector from 

“engag[ing] in any conduct the natural consequence of which 

 

4 The District Court reached the opposite conclusion by

relying on Pescatrice v. Elite Recovery Service, Inc., No. 06-

61130, 2007 WL 1192441 (S.D. Fla. Apr. 23, 2007), and 

Strand v. Diversified Collection Service, Inc., 380 F.3d 316

(8th Cir. 2004). Those cases, however, are distinguishable. 

In Pescatrice, the court held that there was no violation 

of § 1692e(10) when a debt collector used an abbreviation of 

its company name in the return address of a mailing. 2007 WL 

1192441, at *4; see also 15 U.S.C. § 1692e(10) (prohibiting 

“[t]he use of any false representation or deceptive means to 

collect or attempt to collect any debt or to obtain information 

concerning a consumer”); infra Section II.D. Similarly, in 

Strand, the court held that a collection agency’s practice of 

using its initials and corporate logo on an envelope’s exterior 

did not violate § 1692f(8). 380 F.3d at 319; see also 15 U.S.C. 

§ 1692f(8) (prohibiting “[u]sing any language or symbol, other 

than the debt collector’s address, on any envelope when 

communicating with a consumer by use of the mails or by 

telegram, except that a debt collector may use his business 

name if such name does not indicate that he is in the debt 

collection business”). Both of those cases were based on 

different provisions of the FDCPA, and we do not interpret

them as deciding the “true name” question that is at issue here.
13

is to harass, oppress, or abuse any person in connection with 

the collection of a debt.” 15 U.S.C. § 1692d. It too, like 

§ 1692e, contains a non-exhaustive list of prohibited conduct, 

one type of which is “the placement of telephone calls without 

meaningful disclosure of the caller’s identity.” Id. § 1692d(6). 

Here, though the issue is close, we conclude that the District 

Court was correct to rule that the Levinses have not stated a 

claim under § 1692d(6). The voicemail messages provided 

enough information about the caller’s identity for the least 

sophisticated debtor to know that the call was from a debt 

collector and was an attempt to collect a debt. 

The statute does not define “meaningful disclosure[,]”

but in Hart v. Credit Control, LLC, the United States Court of 

Appeals for the Eleventh Circuit interpreted “meaningful 

disclosure” as requiring a debt collector’s voice message to 

provide two types of information: first, “the name of the debt 

collection company[,]” and second, “the nature of the debt 

collection company’s business, which can be satisfied by 

disclosing that the call is on behalf of a debt collection 

company[.]” 871 F.3d 1255, 1260 (11th Cir. 2017). The court 

held that there was no violation of § 1692d(6) when the 

individual calling on behalf of the debt collector did not leave 

his or her personal name in a message because that individual 

provided a company name and stated that the call was from a 

debt collector. Id. at 1259-60; see also id. at 1256 (“This is 

Credit Control calling with a message. This call is from a debt 

collector. Please call us at 866–784–1160. Thank you.”). 

District courts in our Circuit have similarly interpreted 

“meaningful disclosure” as requiring a debt collector “to reveal 

itself as a collection agency when leaving messages” because 

“[m]eaningful disclosure requires a debt collector to disclose 

enough information so as not to mislead the recipient as to the 
14

purpose of the call.” See Pisarz v. GC Servs. Ltd. P’ship, No.

16-4552, 2017 WL 1102636, at *6 (D.N.J. Mar. 24, 2017)

(internal quotation marks and citation omitted); see also id.

(citing district court cases).

The Levinses claim that saying “ARS” was not enough

meaningful disclosure of the caller’s identity to be lawful under 

§ 1692d(6). As with their claim under § 1692e(14), they again 

argue that, from the words of the messages, it is not clear that 

“ARS” would uniquely refer to HRRG because there are other 

companies in the debt collection industry that are associated 

with the name “ARS,” and there are other businesses registered 

in New Jersey with business names or associated names that 

include “ARS.” Although we agreed with that contention with 

respect to § 1692e(14)’s “true name” requirement, it has less 

force in the context of § 1692d(6) for two reasons.

First, although it is possible for a debt collector’s phone 

message to violate both §§ 1692d(6) and 1692e(14),5a 

 

5 The FTC regards a debt collector’s use of “a false 

business name in a phone call” as violating both §§ 1692e(14)

and 1692d(6). See FTC Commentary, 53 Fed. Reg. at 50105

(“A debt collector who uses a false business name in a phone 

call to conceal his identity violates [§ 1692e(14)], as well as 

[§ 1692d(6)].”); id. at 50107 (“When a debt collector uses a 

false business name in a phone call, he violates [§ 1692d(6)] as 

well as [§ 1692e(14)].”). We agree that such conduct would 

violate both §§ 1692e(14) and 1692d(6), but here the Levinses

have not alleged that “ARS” is a “false business name” of 

HRRG. They have only alleged and argued that the name 

“ARS” could refer to any number of companies that use the 
15

violation of one provision is not necessarily a violation of the 

other because “meaningful disclosure of the caller’s identity” 

is not restricted to providing the name of the debt collector. As 

explained above, “meaningful disclosure of the caller’s 

identity” has been interpreted to include information that 

discloses the call is from a debt collector so as not to mislead 

the least sophisticated debtor of the purpose of the call. Here, 

the voicemail messages would not mislead the least 

sophisticated debtor because the messages gave some 

identifying information about the caller, stated that the call was 

from a debt collector, and stated that the call was an attempt to 

collect a debt. Even though the Levinses have sufficiently 

alleged that “ARS” is, as already discussed, less than a “true 

name” as defined by § 1692e(14), they have not plausibly 

alleged that using the abbreviation “ARS,” which is associated 

with a registered identity of HRRG, amounts to a lack of 

meaningful disclosure of the sort forbidden by § 1692d(6). 

Nothing in the messages rises to the level of “harass[ment], 

oppress[ion], or abuse ... in connection with the collection of a 

debt,” which is the target of § 1692d.

Second, and closely related, if we were to say that use 

of anything less than a debt collector’s “true name” was a 

violation of § 1692d(6), we would make § 1692d(6) 

superfluous in light of § 1692e(14). See Everage v. Nat’l 

Recovery Agency, No. 14-2463, 2015 WL 1071757, at *5 (E.D. 

Pa. Mar. 11, 2015) (declining to import § 1692e(14)’s “true 

name” requirement into § 1692d(6)). When Congress enacted 

the FDCPA, it used the term “true name” in § 1692e(14), 

whereas it used “meaningful disclosure of the caller’s identity” 

 

name “ARS,” which falls short of saying that “ARS” is a “false

business name” of HRRG.
16

in § 1692d(6). Fair Debt Collection Practices Act, Pub. L. No. 

95-109, 91 Stat. 874, 877-78 (1977). The difference must have 

significance. If Congress had wanted § 1692d(6) also to 

require that a debt collection company use its “true name[,]” 

then it would have so specified. See Loughrin v. United States, 

134 S. Ct. 2384, 2390 (2014) (noting “when Congress includes 

particular language in one section of a statute but omits it in 

another[,] ... th[e Supreme] Court presumes that Congress 

intended a difference in meaning” (internal quotation marks, 

citation, and alteration omitted)). We will not rewrite the 

statute and import the “true name” requirement of § 1692e(14) 

into § 1692d(6). 

For those reasons, the District Court properly dismissed 

the Levinses’ claim under § 1692d(6).

D. The Levinses Have Not Stated A Plausible 

Claim Under § 1692e(10).

Finally, we also agree with the District Court’s 

conclusion that the Levinses failed to state a claim under 

§ 1692e(10) because the messages adequately warned that any 

information obtained would be used to collect a debt. 

Section 1692e(10) prohibits “[t]he use of any false 

representation or deceptive means to collect or attempt to

collect any debt or to obtain information concerning a 

consumer.” 15 U.S.C. § 1692e(10).

Violations of § 1692e(10) usually “include 

impersonating a public official, falsely representing that 

unpaid debts will be referred to an attorney, and 

misrepresenting the amount of the debt owed.” Harvey v. 

Great Seneca Fin. Corp., 453 F.3d 324, 331 (6th Cir. 2006) 
17

(internal citations omitted); see also, e.g., Crossley v. 

Lieberman, 868 F.2d 566, 571 (3d Cir. 1989) (holding attorney 

violated § 1692e(10) when he sent a collection letter that 

falsely represented that a mortgage foreclosure case was 

already in litigation, that threatened to take action within one 

week, and that failed to inform debtor of her right to cure). To 

state a claim under § 1692e, a false statement “must be material 

when viewed through the least sophisticated debtor’s eyes[,]” 

which means “it has the potential to affect the decision-making 

process of the least sophisticated debtor[.]” Jensen v. Pressler 

& Pressler, 791 F.3d 413, 421 (3d Cir. 2015) (emphasis 

omitted).

Here, nothing in the messages rises to the level of being

materially deceptive, misleading, or false. The plain language

of each message reveals that the caller is a debt collector, that 

the call is part of an attempt to collect a debt, and that any 

information obtained will be used in that attempt. Given those 

clear disclosures, even the least sophisticated debtor is fairly 

on notice that calling the phone number provided in the 

message or visiting the website might result in the debt 

collector obtaining information that it could use in trying to 

collect the debt. The caller’s purpose is transparent and the 

messages are far removed from the false representations that 

typically have been held to violate § 1692e(10). The District 

Court thus properly dismissed the claim brought under that 

FDCPA subsection.

III. CONCLUSION

For the foregoing reasons, we will vacate the District 

Court’s dismissal of the § 1692e(14) claim and remand for 

further proceedings. We will affirm, however, the District 
18

Court’s dismissal of the claims under §§ 1692d(6) and

1692e(10).