The Rosenthal FDCPA (Civ. Code 1788.15(a))  forbids collecting consumer debt by judicial proceedings when the collector knows that service of process, if necessary to establish personal jurisdiction, was not properly effected.  This decision holds that the absolute litigation privilege does not apply to immunize the debt collector from liability under the cited section, which is more specific that Civ. Code 47(b).  It also holds that “knows” as used in most statutes including section 1788.15(a) includes both actual and constructive knowledge.  Here, the debt collector should have known that service was not properly effected because the debtor produced evidence that at least cast the service in doubt and the collector then conducted no investigation to find out whether service was proper–but had it investigated it would have found additional grounds for judging service improper.