In Narog v. Certegy Check Services, Inc., — F.Supp.2d —-, 2011 WL 70595 (N.D.Cal.), Judge Illston found that credit reporting activity occurring after a debt was paid-in-full did not trigger FDCPA issues, explaining: 


It is clear from plaintiff’s pleadings that he has alleged that a debt existed at one time. However, plaintiff complains only of acts or omissions relating to things that plaintiff alleges that defendant should or should not have done on or after May 4, 2009, the date that plaintiff discovered the derogatory mark on his credit report. Although the credit report lists the account as derogatory and having had a 120-day late payment, it also lists the balance of the account at $0. That is to say, at one time there was a debt and it was not paid as promised, but now the is no debt left that needs to be paid off. A plaintiff cannot allege a claim for violation of the FDCPA based on conduct that occurred after he paid his debt in full, and after the debt collector acknowledged that the debt was paid in full. See Winter v. I.C. System Inc., 543 F.Supp.2d 1210, 1213 (S.D.Cal.2008). Under the FDCPA, that conduct is not taken in connection with the collection of a debt.  Therefore, the Court GRANTS defendant’s motion to dismiss.