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Frank Thomas v. Law Firm of Simpson & Cybak, et al.

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This case turns on what constitutes an "initial communication" under the Fair Debt Collection Practices Act (FDCPA). The U.S. District Court for the Northern District of Illinois ruled that filing a summons in a debt collection suit is not a "communication" under FDCPA. The Seventh Circuit Court of Appeals disagreed and remanded the case for further consideration.

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