Woodman v. NPAS Solutions, LLC, 2:22-cv-01540

In 2019 Woodman received medical treatment from Southern Hills and provided a cell number (ending 0880) authorizing billing-related communications.
She did not pay; a debt collector (identified in the record as NPAS Solutions, LLC) placed multiple collection calls (12 calls recorded from July 2020–Jan 2021).
On April 26, 2021 Woodman says she retained counsel and revoked consent for direct contact.
Woodman alleges four additional calls after that date from 800-223-9899 and submitted audio/voicemail transcripts in which the caller identifies as "NPAS" collecting for Southern Hills.
NPAS Solutions denies calling after the revocation and denies owning/using 800-223-9899, contending a different entity (NPAS, Inc.) made the calls; the BBB listing for 800-223-9899 lists NPAS Solutions, creating a factual dispute.
Procedural posture: Woodman sued under the TCPA, the FDCPA, and intrusion upon seclusion; the Court denied NPAS Solutions’ motion for summary judgment, finding genuine disputes of material fact, and ordered a joint pretrial order within 21 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether NPAS Solutions called Woodman after she revoked consent/retained counsel	Audio/voicemails show calls by a collector identifying as "NPAS" after counsel retained	NPAS Solutions’ internal logs show no calls after the revocation; it denies using/owning 800-223-9899 and points to NPAS, Inc.	Denied summary judgment — genuine dispute of material fact exists as to whether calls occurred after revocation
Whether NPAS Solutions owned/used 800-223-9899 (identity of caller)	BBB listing and call content indicate NPAS Solutions is the number owner/caller	Calls were made by a different, similarly named entity (NPAS, Inc.); NPAS Solutions disclaims ownership/use	Court finds the BBB record and plaintiff’s recordings create a triable dispute over ownership/identity
Whether continued calls could constitute an FDCPA §1692d violation	Continued calls after a cease/attorney notice would constitute harassment under §1692d	If NPAS Solutions did not call after revocation, no §1692d violation occurred	Summary judgment inappropriate on §1692d claim because a factual dispute exists over whether calls continued

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (establishes summary judgment standard; evaluating genuine issues of material fact)
Celotex Corp. v. Catrett, 477 U.S. 317 (burden-shifting framework for summary judgment)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (movant’s evidentiary showing and inference-drawing limitations)
T.W. Elec. Serv., Inc. v. Pac. Elec. Contractors Ass'n, 809 F.2d 626 (nonmoving party need only show factual dispute requiring resolution at trial)
Diaz v. Eagle Produce Ltd. P'ship, 521 F.3d 1201 (Ninth Circuit on drawing inferences for nonmoving party)
C.A.R. Transp. Brokerage Co. v. Darden Rests., Inc., 213 F.3d 474 (movant-with-trial-burden standard at summary judgment)
Aydin Corp. v. Loral Corp., 718 F.2d 897 (evidence threshold to raise genuine issue of material fact)