In Cordes v. Frederick J. Hanna & Associates, P.C, 2011 Wl 2214939 (D. Minn. 2011), Judge Kyle followed Zortman v. J.C. Christensen & Assoc., Inc., 2011 WL 1630935 (D. Minn. 2011) in holding a debt collector liable for inadvertent disclosure to third parties by way of voicemail messages left on an answering machine. Judge Kyle rejected the debt collector’s argument that ‘it cannot be liable here absent intentional or deliberate disclosure’ to the third parties.