Mack v. Resurgent Capital Services, L.P. 

Dist. Ct. erred in granting defendant-debt-collector’s motion to dismiss for lack of standing plaintiff-debtor’s action under Fair Debt Collection Practices Act (FDCPA), alleging that defendant’s second dunning letter violated FDCPA, where it failed to validate plaintiff’s debt (after she had sent letter to defendant seeking said validation) and improperly required that she send second letter seeking said validation. While plaintiff alleged that she became confused and alarmed after receiving second letter, and while Dist. Ct. based dismissal on finding that plaintiff’s confusion and alarm were insufficient injuries to establish requisite standing to bring instant action, Ct. of Appeals held that plaintiff adequately alleged injury-in-fact to support her standing to bring instant lawsuit, where plaintiff asserted that she incurred $3.95 additional postage for sending second request for validation of her debt. As such, plaintiff adequately pleaded concrete harm to underlying interest covered by FDCPA that concerned money damages caused by alleged misleading communications contained in second dunning letter.