The following excerpt is from Udo v. Kelkris Assocs., Inc., CASE NO. 12-CV-2022- IEG (NLS) (S.D. Cal. 2012):
To be so covered, "at a minimum, a 'transaction' under the FDCPA must involve some kind of business dealing or other consensual obligation." Id.; see also Waters v. Howard Sommers Towing, Inc., 2011 WL 1375292, at *7 (C.D. Cal. April 11, 2011) ("the law in this circuit is that for purposes of the FDCPA debt is incurred when a consumer engages in a consensual transaction:
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