Alexandra Jewsevskyj brought a putative class action against Financial Recovery Services, Inc. ("FRS"), LVNV Funding, Inc., Resurgent Capital Services, L.P., and Alegis Group, LLC (collectively, "Defendants"), claiming that FRS did not provide Jewsevskyj adequate notice of her right to contest an alleged consumer debt, as required by § 1692g of the Fair Debt Collection Practices Act ("FDCPA"), 15 U.S.C. § 1692g. Jewsevskyj appeals the District Court's order granting summary judgment in favor of Defendants, in which the Court concluded that a letter sent by FRS satisfied the statutory notice requirements. Although the letter is printed in a small typeface and the words and spacing are compressed, the language is clear and effectively conveyed to Jewsevskyj her § 1692g rights. Therefore, we will affirm.1
LVNV Funding is a corporation that purchases portfolios of consumer debt from various creditors and hires debt collection agencies to recover the moneys owed. FRS is one such debt collection agency.2 FRS sent a letter to Jewsevskyj advising her that LVNV Funding purchased a debt she owed in the amount of $1,128. The body of the letter is typed in all uppercase letters, in Times New Roman style, and in 8-point font.3 There is minimal spacing between the lines in each of the three full paragraphs on the front page and thus the text is compressed. The second paragraph of the letter contains what is commonly referred to as the "validation notice," which describes a mechanism for Jewsevskyj to contest the debt.4
Jewsevskyj filed a class action complaint, alleging that this validation notice was not sufficiently prominent or readable to satisfy the statutory notice requirements of § 1692g. After discovery, the parties filed cross-motions for summary judgment. The District Court granted Defendants' motion and denied Jewsevskyj's, finding that, from the perspective of the "least sophisticated debtor," the validation notice was not overshadowed by other aspects of the letter and was sufficiently prominent to put Jewsevskyj on notice of her right to contest the debt. Jewsevskyj appeals.
Congress passed the FDCPA to "eliminate abusive debt collection practices by debt collectors." 15 U.S.C. § 1692(e); see also id. § 1692(a) ("There is abundant evidence of the use of abusive, deceptive, and unfair debt collection practices by many debt collectors."); Wilson v. Quadramed Corp., 225 F.3d 350, 354 (3d Cir. 2000). One way the FDCPA accomplishes this goal is by requiring that debt collectors provide certain information to consumers about their rights and obligations, including their right to seek information about and dispute a debt. See § 1692g. Congress specifically provided a means by which a consumer can obtain information about a debt through the debt validation provisions of § 1692g. Caprio v. Healthcare Revenue Recovery Grp., LLC, 709 F.3d 142, 148 (3d Cir. 2013). Under § 1692g, a consumer must be told that he or she may dispute a debt and that the debt collector will provide the consumer with documents that verify the existence of the debt, list the amount of the debt, and identify the creditor.6
To comply with § 1692g, more is required than merely reciting the words of the statutory debt validation notice provisions in the debt collection letter. Wilson, 225 F.3d at 354. "[T]he required notice must also be conveyed effectively to the debtor." Id. Whether the validation notice is effectively conveyed to the debtor is evaluated "from the perspective of the `least sophisticated debtor.'" Graziano v. Harrison, 950 F.2d 107, 111 (3d Cir. 1991). The fundamental purpose of this standard is to ensure that the statute "protects all consumers, the gullible as well as the shrewd." Caprio, 709 F.3d at 149. The least sophisticated debtor standard is therefore "less demanding than one that inquires whether a particular debt collection communication would mislead or deceive a reasonable debtor." Campuzano-Burgos v. Midland Credit Mgmt., Inc., 550 F.3d 294, 298 (3d Cir. 2008). Nevertheless, "the standard does not go so far as to provide solace to the willfully blind or non-observant," and so "the least sophisticated debtor is bound to read collection notices in their entirety." Id. at 299.
Though the debtor is expected to read the collection letter, reviewing the validation notice must not be a struggle: instead, it "must be in print sufficiently large to be read, and must be sufficiently prominent to be noticed" by the least sophisticated debtor. Graziano, 950 F.2d at 111; see also Wilson, 225 F.3d at 355. Moreover, "the notice must not be overshadowed or contradicted by accompanying messages from the debt collector." Graziano, 950 F.2d at 111. A communication overshadows the validation notice when other language and/or physical characteristics of the letter feature more prominently than does the notice. See Wilson, 225 F.3d at 356. A communication contradicts the validation notice when it provides information inconsistent with the consumer's right to dispute the debt. See id. "[W]hether language in a collection letter contradicts or overshadows the validation notice is a question of law." Id. at 353 n.2.
Here, although the format is compressed and the font is small, our inquiry focuses on whether the notice is free from language or formatting choices that contradicts or overshadows the notice.7 There is no language that contradicts the notice and the recipient's right to obtain information about the debt. Moreover, because the notice language is in the same font and format as the rest of the letter, there is nothing more prominent than the notice. See Wilson, 225 F.3d at 356 (holding that validation notice "presented in the same font, size and color type-face" as the rest of the letter did not violate § 1692g). Furthermore, the notice is placed on the first page of the letter and is written in plain English. While font size and format could render a notice unreadable, we cannot conclude that the notice here fits in that category as it is concise and legible, and is not misleading, confusing, or overshadowed by anything else in the letter. Cf. Graziano, 950 F.2d at III (concluding that demand on front of letter which contradicted validation notice on reverse side did not effectively communicate rights under § 1692g). Thus, the District Court correctly concluded that the letter does not violate § 1692g.
For the foregoing reasons, we will affirm.