Beeders v. Gulf Coast Collection Bureau, 796 F. Supp. 2d 1335

Beeders sued Gulf Coast Collection Bureau for FDCPA violations arising from calls and messages in 2007–2008.
Approximately 40 automated calls were made, with about 15 voice messages left.
Ten messages were recorded; all followed a substantially similar script directing Beeders to call file number G31852.
Calls occurred 8:00–11:00 a.m., no more than one call per day and no more than one every two days.
Plaintiff eventually asked to stop calls; defendant complied; plaintiff’s credibility on earlier stop requests was disputed.
Court analyzed whether calls were harassing (1692d(5)) and whether disclosures in messages satisfied 1692d(6) and 1692e(11).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether calls violated FDCPA 1692d(5).	Beeders contends volume/pattern amount to harassment.	Calls were not intended to harass; volume moderate.	No violation; calls not egregious harassment.
Whether messages violated FDCPA 1692d(6).	Messages failed to disclose debt-collection identity.	Alias plus identification of Gulf Coast Collection Bureau sufficed.	No violation; disclosures sufficient in context.
Whether messages violated FDCPA 1692e(11).	Messages did not clearly identify debt-collection purpose.	Company name and context reasonably informed unsophisticated consumer of debt-collection purpose.	No violation; context satisfied least sophisticated consumer standard.

Jeter v. Credit Bureau, Inc., 760 F.2d 1168 (11th Cir. 1985) (least sophisticated standard for FDCPA disclosures)
Drossin v. National Action Financial Services, Inc., 641 F. Supp. 2d 1314 (S.D. Fla. 2009) (assessing 1692e(11) disclosures in messages)
Hosseinzadeh v. M.R.S. Assocs., Inc., 387 F. Supp. 2d 1104 (C.D. Cal. 2005) (alias disclosures and debt-collection identity requirements)
Joseph v. J.J. Mac Intyre Cos., 281 F. Supp. 2d 1156 (N.D. Cal. 2003) (importance of identifying debt-collection purpose in messages)