White v. Rentdebt Automated Collections, 3:16-cv-00647

Plaintiff Destry White allegedly broke a lease with Bridgewood Townhomes in 2013; Bridgewood placed the resulting debt with Rentdebt Automated Collections, LLC (RDAC) for collection in January 2014.
White sent a May 18, 2016 letter to RDAC disputing the debt and demanding verification and that RDAC contact CRAs to remove an inquiry; RDAC replied May 23, 2016 with a letter attaching the signed lease, residency application, itemized transaction form, and placement form.
White sent a second letter July 25, 2016 demanding $4,000 or threatened suit; RDAC responded that it had already investigated and no new investigation was warranted absent new allegations.
On August 26, 2016 White sent a cease-communication letter under 15 U.S.C. § 1692c(b); RDAC asserts it then ceased communications until suit was filed.
White sued (Oct. 12, 2016) alleging violations of the FDCPA, FCRA, and Kentucky Consumer Protection Act (KCPA); RDAC moved for summary judgment and White filed a cross-motion but did not engage in discovery.
The court found RDAC’s summary-judgment showing adequate, dismissed all claims with prejudice, granted RDAC’s motion, and denied White’s motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RDAC violated FDCPA §1692g by failing to verify the debt	White contended RDAC failed to validate the debt and that the documents produced were insufficient	RDAC produced an itemized accounting, the signed lease, application, and placement form, arguing that sufficed as verification	Court: RDAC satisfied §1692g(b); verification adequate, FDCPA validation claim dismissed
Whether RDAC committed other FDCPA violations (§1692c, §1692d, §1692e, §1692f)	White alleged harassment, false/misleading statements, improper communications, and unfair practices (some claims asserted in briefs)	RDAC denied any abusive, misleading, unfair, or improper communications; White offered no evidentiary support	Court: No evidence of these violations; claims dismissed
Whether RDAC violated FCRA §1681s‑2 by failing to investigate/notify CRAs	White argued furnishers must investigate disputes and remove inquiries	RDAC argued a furnisher’s duty under §1681s‑2(b) is triggered only after notice from a CRA, and White never contacted a CRA	Court: White did not notify any CRA; FCRA claims fail as a matter of law
Whether RDAC violated KCPA	White alleged KCPA violations arising from the collection activity	RDAC noted it is a third‑party collector and not in privity with White	Court: KCPA claims require privity; RDAC not in privity; KCPA claims dismissed

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden on movant)
Anderson v. Liberty Lobby, 477 U.S. 242 (genuine issue for trial standard)
Matsushita Elec. Indus. Co. v. Zenith Radio, 475 U.S. 574 (view evidence in light most favorable to nonmovant)
Haddad v. Alexander, Zelmanski, Danner & Fioritto, PLLC, 748 F.3d 777 (6th Cir.) (itemized accounting can satisfy §1692g(b) verification)
Boggio v. USAA Fed. Sav. Bank, 696 F.3d 611 (6th Cir.) (private FCRA action against furnisher requires notice from CRA)
Stafford v. Cross Country Bank, 262 F. Supp. 2d 776 (W.D. Ky.) (furnisher duty to investigate triggered by CRA notice; consumer notice insufficient)
Naiser v. Unilever United States, Inc., 975 F. Supp. 2d 727 (W.D. Ky.) (KCPA privity requirement and scope)
Skilcraft Sheetmetal, Inc. v. Ky. Mach., Inc., 836 S.W.2d 907 (Ky. Ct. App.) (KCPA privity interpretation)