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7th Circuit's Lavallee v. Med-1 Solutions Decision: What You Need to Know

Posted By Administration, Friday, August 16, 2019
Updated: Thursday, January 2, 2020

Recorded Friday, August 16, 2019

On August 8, 2019, the 7th Circuit Court of Appeals (7th Cir.) published its opinion in the matter of Beth Lavallee v. Med-1 Solutions, LLC. The appeal "rests on Med-1’s contention that its emails were initial communications that contained the required disclosures. But the emails do not qualify under the Act’s definition of “communication” because they did not “convey[] … information regarding a debt.” 15 U.S.C. § 1692a(2). Nor did the emails “contain” the statutorily mandated disclosures. § 1692g(a). At most the emails provided a means to access the disclosures via a multistep online process."  Because Med-1 violated § 1692g(a), the 7th Cir. found the judge was right to enter judgment for Lavallee.

In this podcast, Nicole Strickler and Stephanie Strickler with Messer Strickler, Ltd. discuss what this decision means for the creditors rights industry, and the text messaging and call frequency limits as outlined in the Consumer Financial Protection Bureau's (CFPB) Notice of Proposed Rulemaking (NRPM) for debt collection.

Listen to the podcast


Nicole M. Strickler

Nicole M. Strickler concentrates her practice on the defense of consumer financial services litigation throughout the country. This includes representing clients in both individual and class actions involving federal consumer laws, including the Fair Debt Collection Practices Act ("FDCPA"), Fair Credit Reporting Act (“FCRA”), Telephone Consumer Protection Act (“TCPA”), Electronic Funds Transfer Act (“EFTA”) and related state laws. She also has significant experience in dealing with federal and state regulators. Her clients include corporations, lending institutions, collection agencies, asset purchasers, attorneys as well as individuals. She is a frequent author and speaker on issues affecting the credit and collection industry.”


Stephanie Strickler

Stephanie Strickler joined Messer Strickler, Ltd. as an associate in 2013. She is a graduate of the University Of Dayton School Of Law where she was a staff writer and comment editor for the University of Dayton Law Review. She concentrates her practice in business litigation, breach of contract, employment law, and consumer defense litigation. Ms. Strickler has defended lawsuits involving state and federal consumer laws, including the Fair Debt Collection Practices Act (“FDCPA”), the Fair Credit Reporting Act (“FCRA”), the Telephone Consumer Protection Act (“TCPA”) and the Illinois Collection Agency Act. 

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