In Sasscer v. Donnelly, 2011 WL 1522320 (M.D.Pa. 2011), Judge Munley explained what ‘validation’ is required in response to a consumer request under the FDCPA:


The Third Circuit, then, has found sufficient a verification that informs the debtor of “the amounts of his debts, the services provided to produce those debts,” and “the dates on which the debts were incurred.” Id. Other Courts of Appeals have imposed similar standards. The Fourth Circuit Court of Appeals has concluded that “verification of a debt involves nothing more than the debt collector confirming in writing that the amount demanded is what the creditor is claiming is owed; the debt collector is not required to keep detailed files of the alleged debt.” Chaudhry v.. Gallerizzo, 174 F.3d 394, 406 (4th Cir.1999). In Chaudry, the court found it sufficient for verification that defendant “forwarded a copy of the bank’s computerized summary of [plaintiffs’] loan transactions” that “included a running account of the debt amount, a description of every transaction, and the date on which the transaction occurred.” Id. The defendant later confirmed by letter the correctness of other added fees. Id. “Nothing more is required,” the court concluded. Id. See also, Clark v. Capital Credit & Collection Servs., 460 F.3d 1162, 1173–74 (9th Cir.2006) (adopting the standard of Chaudry as “the minimum” for verifying the debt, and approving a verification that involved “obtain[ing] information … about the nature and balance of the outstanding bill and provid [ing] [plaintiffs] with documentary evidence in the form of the itemized statement.”); Maynard v. Bryan w. Cannon, P.C., 401 Fed. Appx. 389, 397 (10th Cir.) (holding that the section “is not intended to give a debtor a detailed accounting of debt to be collected” but instead that “ ‘verification is intended to eliminate the problem of debt collectors dunning the wrong person or attempting to collect debts which the consumer has already paid.’ ”) (quoting Chaudhry, 174 F.3d at 406). The Court will apply this standard to plaintiff’s motion.  ¶ . . . At the least, there is a disputed question of fact as to the adequacy of this verification. The parties agree that the defendant provided plaintiff with some information on the validity of the debt. The defendant provided plaintiff with a copy of the loan contract. The parties disagree about whether plaintiff actually received much of the information defendant claims he provided. While the information allegedly provided by defendant in his December 2, 2009 letter may well have been sufficient to verify the debt, there is a dispute of fact as to whether plaintiff ever received that information. Similarly, there is a factual dispute about whether defendant filed suit in state court before verifying the debt. If defendant mailed the disputed second letter to plaintiff before filing suit, a jury could conclude that he verified the debt before filing the state court action. Since a question of fact exists over whether defendant actually verified the debt and then filed suit, the court will deny plaintiff’s motion on this point.