Cordes v. Frederick J. Hanna & Associates, P.C., 789 F. Supp. 2d 1173

Cordes lived with her boyfriend and a friend who shared the home voicemail; Hanna left multiple debt-collection voicemails that were heard by others.
Cordes incurred Chase credit-card debt and, after default, Chase assigned the account to Hanna for collection.
Between December 3, 2009 and January 20, 2010 Hanna left seven messages identifying itself as a debt collector.
Hanna sent a February 9, 2010 letter on firm letterhead offering a settlement; none of Hanna's twelve attorneys reviewed Cordes's file before the letter was sent.
Cordes sued under the FDCPA alleging §1692c(b) improper third-party communications and §1692e(3) false implication of attorney review; Cordes moved for partial summary judgment on Hanna's liability, which the court granted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether voicemails to third parties violated §1692c(b).	Cordes argues Hanna communicated with third parties during collection.	Hanna contends there was no intentional disclosure to third parties.	Cordes granted judgment on liability under §1692c(b).
Whether the letter on firm letterhead violated §1692e(3).	Cordes argues the letter falsely implied attorney review despite no attorney involvement.	Hanna asserts form-letter content was generated by an attorney and involved standard procedures.	Cordes granted judgment on liability under §1692e(3).

Clomon v. Jackson, 988 F.2d 1314 (2d Cir. 1993) (letters on attorney letterhead imply meaningful attorney involvement)
Avila v. Rubin, 84 F.3d 222 (7th Cir. 1996) (attorney involvement required for 'from' attorney implication)
Duffy v. Landberg, 215 F.3d 871 (8th Cir. 2000) (unsophisticated-consumer standard for FDCPA letters)
Greco v. Trauner, Cohen & Thomas, L.L.P., 412 F.3d 360 (2d Cir. 2005) (law firm letterhead conveys attorney involvement; disclaimers may negate)