In Zemeckis v. Global Credit & Collection Corp. — F.3d —-, 2012 WL 1650479 (7th Cir. 2012), the Court of Appeals for the Seventh Circuit addressed what constitutes puffery or material misrepresentations in a collection letter under the FDCPA. To summarize, the Court of Appeals held that (1) suggestions in dunning letter, for debtor to “take action now” and call “today,” were puffery that did not violate debt validation provision of FDCPA; (2) warning in debt collector’s dunning letter, that creditor had right to pursue legal action against debtor, did not violate debt validation provision of FDCPA; (3) locating debt validation notice on back of letter did not engender confusion sufficient to state claim under FDCPA; and (4) consideration of consumer survey was not warranted.