OPINION OF THE COURT
SHWARTZ, Circuit Judge.
Timothy McLaughlin had a mortgage. As a result of an error, the mortgage company believed that he was in default and referred the matter to the law firm Phelan Hallinan & Shmieg, LLP, whose lawyers include Lawrence T. Phelan, Francis S. Hallinan, Daniel G. Schmieg, and Rosemarie Diamond (collectively "PHS"). PHS sent McLaughlin a letter about the debt that he claims violated the
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