9th Cir. Says Request for Contact in Validation Letter Did Not Overshadow 30-day Notice

Stuppiello complains of a letter in which the Defendant-Appellee informed him that a $612.32 debt “[was] due in full.” In that letter, the Defendant-Appellee also wrote “[w]e are willing to work with you, but you must contact our office promptly. Avoid further collection activity by enclosing your payment … or by contacting us … to make payment arrangements on your account.”. . . Yet the notice is not threatening, does not limit the time in which Stuppiello can dispute the debt, and is in the same font as his FDCPA rights. Compare Mashiri, 845 F.3d at 991; Swanson, 869 F.2d at 1225–26. The notice, therefore, does not violate the FDCPA. See, e.g., Renick v. Dun & Bradstreet Receivable Mgmt. Servs., 290 F.3d 1055, 1057 (9th Cir. 2002) (per curiam); see also Terran, 109 F.3d at 1434.  And contrary to Stuppiello’s assertions, the notice would not confuse the least sophisticated debtor about his FDCPA rights. Stuppiello contends—without citing any Ninth Circuit authority in support—that validation notices must include transitional language, i.e. language explaining that a request for payment does not limit a consumer’s right to challenge a debt within thirty days. We have never imposed such a requirement, and decline to do so now. As Stuppiello’s FDCPA and dependent Rosenthal Fair Debt Collection Practices Act claims lack merit, we affirm the district court’s grant of the Defendant-Appellee’s summary judgment motion.