Gruber v. Creditors' Protection Service, Inc., 742 F.3d 271

Four plaintiffs received debt-collection letters (2012–2013) containing the statutory 30-day validation language but with a second sentence that omitted the phrase “that the debt, or any portion thereof, is disputed.”
The second sentence instead said the consumer should "notify" within 30 days and the office would obtain verification or a copy of a judgment and mail it to the consumer.
One letter also prefaced the validation language with: "We believe you want to pay your just debt."
Plaintiffs sued under the Fair Debt Collection Practices Act, § 1692g(a)(4), arguing the letters misled consumers into requesting verification (rather than disputing the debt) and that the “just debt” phrase was misleading/overshadowing.
District and magistrate judges in the Eastern District of Wisconsin dismissed for failure to state a claim; appeals were consolidated.
The Seventh Circuit affirmed, holding the letters complied with § 1692g(a)(4) and that the “just debt” language was mere puffery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the second sentence violated § 1692g(a)(4) by omitting the phrase that the debt "is disputed"	Omission risks misleading an unsophisticated consumer to request verification instead of disputing the debt, thus failing to give required notice	A consumer’s written request for verification is treated as a "dispute" under the Act; unsophisticated consumers need not use legalistic phrasing	Held: No violation. A request for verification counts as a dispute; notice complies with § 1692g(a)(4)
Whether the phrase "We believe you want to pay your just debt" misleads or overshadows the statutory notice	Phrase suggests the debt is confirmed or a judgment exists and thus is misleading/overshadowing	Phrase is non-actionable puffery and does not contradict or shorten the 30‑day validation right	Held: No violation. The phrase is puffery and not misleading in context

Bartlett v. Heibl, 128 F.3d 497 (7th Cir. 1997) (unsophisticated-consumer standard and confusing collection-letter analysis)
Avila v. Rubin, 84 F.3d 222 (7th Cir. 1996) (contrasting a notice that created inconsistent time demands)
Pettit v. Retrieval Masters Creditor Bureau, Inc., 211 F.3d 1057 (7th Cir. 2000) (description of the unsophisticated consumer standard)
DeKoven v. Plaza Assocs., 599 F.3d 578 (7th Cir. 2010) (holding a verification request qualifies as a "dispute")
Horkey v. J.V.D.B. & Assocs., Inc., 333 F.3d 769 (7th Cir. 2003) (consumers need not use precise legal phrasing to assert rights)
Zemeckis v. Global Credit & Collection Corp., 679 F.3d 632 (7th Cir. 2012) (dismissal required unless a significant fraction of the population would be misled)
Taylor v. Cavalry Inv., LLC, 365 F.3d 572 (7th Cir. 2004) (puffery does not violate § 1692g)
Chauncey v. JDR Recovery Corp., 118 F.3d 516 (7th Cir. 1997) (inconsistent timing in letters can be misleading)
Chuway v. Nat. Action Fin. Servs., Inc., 362 F.3d 944 (7th Cir. 2004) (confusion over amount due and references to a separate source of current balance)