In Monahan v. NRA Group L.L.C., 2011 WL 3901877 (D.Conn. 2011), Judge Hall found that a debt collector’s statements that collections would continue were not oppressive to the debtor:


Section 1692d is meant to protect debtors from oppressive and outrageous conduct, but not from every negative consequence of debt collection. See Bieber v. Assoc. Collection Servs., Inc., 631 F .Supp. 1410, 1417 (D.Kan.1986) (“Some inconvenience or embarrassment to the debtor is a natural consequence of debt collection.”). Courts have interpreted section 1692d(2) to prohibit profanity and obscenity, as well as offensive language that is akin to profanity or obscenity. See Jeter, 760 F.2d at 1178 (“Such offensive language might encompass name-calling, racial or ethnic slurs, and other derogatory remarks which are similar in their offensiveness to obscene or profane remarks.”). A court may rule as a matter of law that particular conduct does not go so far as to violate section 1692d(2). See Jeter, 760 F.2d at 1179–80; Unterreiner v. Stoneleigh Recovery Assocs., LLC, 2010 WL 2523257 at *1–2 (N.D. Ill. June 17, 2010) (finding conduct does not violate section 1692d(2) where plaintiff alleges a debt collection agency employee screamed at her and asked, “how could you go and max out a card like that?”); Thomas v. LDG Fin. Servs., LLC, LLG, 463 F.Supp.2d 1370, 1373 (N.D.Ga.2006) (finding plaintiff fails to state a claim where defendants yelled at her and told her “they were going to get their money one way or another”).     Monahan asserts that NRA violated section 1692d(2) with statements such as: “activity is going to keep on coming, that’s what we do;” “[we will] just call and call until she can pick up;” and “further collections will continue.” See Mem. Opp. Summ. J. at 9.FN5 Monahan admits that no NRA representative used profanity, called her names, or screamed at her. L.R. 56(a) Stmt. ¶¶ 5–6. Even employing the least sophisticated consumer standard, and taken in the light most favorable to Monahan, these statements are not akin to obscenity or profanity. Accordingly, Monahan fails to raise a material issue of fact to support her claim that NRA’s statements went so far as to violate section 1692d(2).