The following excerpt is from Naranjo v. SBMC Mortg., Case No. 11-cv-2229-L(WVG) (S.D. Cal. 2012):
"The [FDCPA] prohibits debt collector[s] from making false or misleading representations and from engaging in various abusive and unfair practices." Heintz v. Jenkins, 514 U.S. 291, 292 (1995). To be liable for an FDCPA violation, a defendant must, as a threshold matter, be a "debt collector" within the meaning of those acts. Id. at 294.
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