Discovery rule tolling applies to the FDCPA’s one-year statute of limitations.  Mangum v. Action Collection Service, Inc., 575 F.3d 935 (9th Cir. 2009).  Here, plaintiff sued based on defendant’s having filed a collection action in a county where the contract was not made and she did not live.  Because plaintiff discovered the suit only when it was served on her, the limitations period began to run at that time, not the earlier date on which the collection action complaint was filed.  Naas v. Stolman, 130 F.3d 892 (9th Cir. 1997) does not hold to the contrary.  Discovery rule tolling was not raised in that case.