Dist. Ct. did not err in dismissing for lack of standing plaintiff’s action, alleging that defendant-debt collector violated section 1692c(b) of Fair Debt Collection Practices Act (FDCPA) by communicating with third-party vendor certain information regarding plaintiff’s credit card debt, where said information was contained in dunning letter that was printed and mailed by vendor. While section 1692c(b) precludes debt collectors from communicating in connection with collection of debt with any person other than consumer/debtor without consumer’s permission, plaintiff failed to show that she experienced any concrete injury arising out of said alleged violation of FDCPA. Moreover, while plaintiff asserted that said disclosure to vendor violated her right to privacy, Ct. of Appeals held that no such violation occurred under instant complaint, which was devoid of any allegations that defendant revealed her private information to general public, especially where final recipient of instant letter was plaintiff.
Federal 7th Circuit Court
Civil Court
Standing