Affirmed by published opinion. Judge ERVIN wrote the opinion, in which Judge RUSSELL and Judge NORTON joined.
OPINION
ERVIN, Circuit Judge:
National Financial Services, Inc. (NFS), Robert J. Smith, and N. Frank Lanocha are debt collectors who, primarily on behalf of companies selling magazine subscriptions, send out computer-generated dunning letters en masse. They appeal the imposition of civil penalties for violations of the Fair Debt Collection...
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