In Hooks v. Forman, Holt, Eliades & Ravin, No. 12-3639-cv (May 29, 2013), the Second Circuit has held that a debt collector's
collection notice violated the Fair Debt Collection Practices Act by stating that the
plaintiffs could only dispute the validity of a debt in writing. The court's ruling is consistent with earlier Ninth Circuit precedent but at odds with Third Circuit precedent.