In Deleon v. Action Collection Agency of Boston, 2018 WL 2089343 (S.D.N.Y., 2018), Judge Abrams found that a debt collector’s dunning letter identified the creditor properly when it used the creditor’s acronym.
The fact that the Letter identifies the creditor by an acronym does not alter this conclusion. To comply with the FDCPA, “a creditor may use the name under which it usually transacts business, or a commonly-used acronym, or any name that it has used from the inception of the credit relation. . . . [A] debt collector need not necessarily use the creditor’s full legal or business name in its collection notices sent to consumers.” Hernandez v. Prof’l Claims Bureau, Inc., 2017 U.S. Dist. LEXIS 193819, at *8–9 (S.D.N.Y. Sep. 23, 2017) (citations and quotation marks omitted). Here, the creditor is identified in the Letter as GPDDC, LLC, the name of GPDDC’s legal entity and the name it uses “in the course of its business.” Gonsalves Aff., ¶¶ 8–11, Ex. A. The acronym “GPDDC” is also featured prominently on the organization’s website, including just below the official logo, Id., Ex. A. Indeed, the “About” section of the website is titled “ABOUT GPDDC.” Id. The use of the name “GPDDC, LLC” in the Letter thus adequately identifies the creditor. In sum, the Letter complied with § 1692g(a)(2). Defendant’s motion for summary judgment on this claim is therefore granted.