In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision. Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

[Q]: how much more of a connection to interstate commerce, if any, must be shown under a substantial rather than a de minimis standard. See Russell, 471 U.S. at 859-60 n. 4, 105 S.Ct. 2455 (suggesting in a pre-Lopez opinion that, under the Commerce Clause, Congress could only reach criminal activity " 'substantially affecting interstate commerce.' "). It is clear, however, that the direct interstate connection required by Instruction 10 is much more substantial than the indirect interstate connection articulated by the government and disapproved of by the Court in Lopez. In Lopez, the connections articulated by the government between the possession of a firearm in a local school zone and interstate commerce were, to say the least, attenuated. See Lopez, 514 U.S. at 567, 115 S.Ct. 1624 (<HOLDING>); see also Hicks, 106 F.3d at 189 (describing
Holding statements: (A) holding that a reasonable inference need not be the sole possible inference (B) holding that adverse inference rule is permissive (C) recognizing that a vital fact may not be established by piling inference upon inference (D) holding that the nonmovant need not be given the benefit of every inference but only of every reasonable inference (E) recognizing that to uphold the government contentions would require the court to pile inference upon inference
[A]: holding that a reasonable inference need not be the sole possible inference

[Q]: defendant's activities fall outside the FDCPA's general provisions); Overton v. Foutty & Foutty, LLP, No. 1:07-cv0274-DFHTAB, 2007 WL 2413026, at *4 (S.D.Ind. Aug. 21, 2007) (recognizing majority position that party whose activities are limited to enforcement of security interests is not subject to all FDCPA requirements, and stating, "[i]f a person invokes judicial remedies only to enforce the security interest in property, then the effort is not subject to the FDCPA (other than 1692f(6) and 1692i(a))[,] [b]ut if the person is also seeking additional relief, such as a personal judgment against the borrower, then the FDCPA applies.") (collecting cases); Chomilo v. Shapiro, Nordmeyer & Zielke, LLP, Civ. No. 06-3103 (RHK/AJB), 2007 WL 2695795, at *6 (D.Minn. Sept. 12, 2007) (<HOLDING>); Acosta v. Campbell, No. 6:04CV761 ORL28DAB,
Holding statements: (A) holding that law firm executing nonjudicial foreclosure pro ceeding was enforcing a security interest rather than collecting a debt and hence fell outside the ambit of the fdcpa except for the provisions of section 1692f6 (B) recognizing distinction between general debt collection and enforcement of a security interest and observing that by the plain language of 1692a6 a person whose business has the principal purpose of enforcing security interests but who does not otherwise satisfy the definition of a debt collector is subject only to 1692f6 (C) holding that a debt collectors filing of a lawsuit on a debt that appears to be timebarred is an unfair and unconscionable means of collecting the debt (D) holding that the defendants actions in filing judicial foreclosure proceeding against mortgagor amounted to debt collection activity under the fdcpa and distinguishing decisions involving pursuit of nonjudicial foreclosure proceedings under a deed of trust from those in which a defendant has pursued judicial foreclosure proceedings which included seeking judgment on a note by filing a lawsuit in state court (E) holding that back rent is debt under the fdcpa
[A]: recognizing distinction between general debt collection and enforcement of a security interest and observing that by the plain language of 1692a6 a person whose business has the principal purpose of enforcing security interests but who does not otherwise satisfy the definition of a debt collector is subject only to 1692f6

[Q]: with putative class members). Indeed, a district court's authority under Rule 23(d) is not limited to communications that actually mislead or otherwise threaten to create confusion, but extends to communications that interfere with the proper administration of a class action or those that abuse the rights of members of the class. Cobell v. Norton, 212 F.R.D. 14, 19 (D.D.C.2002). "A unilateral communications scheme, moreover, is rife with potential for coercion. If the class and the class opponent are involved in an ongoing business relationship, communications from the class opponent to the class may be coercive." Kleiner, 751 F.2d at 1202 (internal quotations, citations and brackets omitted); see also Hampton Hardware v. Cotter & Co., 156 F.R.D. 630, 633-34 (N.D.Tex.1994) (<HOLDING>); Tedesco v. Mishkin, 629 F.Supp. 1474, 1484
Holding statements: (A) holding that tolling applies to a subsequent class action when class certification was granted in a prior case (B) holding that putative class members are not parties to an action prior to class certification (C) holding evidence of letters discouraging participation in lawsuit an ongoing business relationship between the parties and plaintiffs dependence on defendant for supplies sufficient to prohibit all litigationrelated communication prior to class certification (D) recognizing a defendants connection to dc because the plaintiff had argued and provided correspondence between the parties demonstrating an ongoing relationship between the parties including the defendant giving the plaintiff directions regarding other business projects that the defendant intended to pursue and argued that the contract would have been at least partly performed within dc (E) recognizing correspondence appeared to establish a settlement relationship between the parties given the letters presented an attempt to curb further litigation
[A]:
holding that tolling applies to a subsequent class action when class certification was granted in a prior case