Oct.16, 1998) (holding that use of language "immediate collection" in a dunning letter does not communicate a demand for immediate payment or a threat of immediate action and therefore does not violate FDCPA). Vasquez v. Gertler Gertler, Ltd., 987 F. Supp. 652, 657 (N.D.Ill. 1997), is also on point. The dunning letter at issue in Vasquez was largely comprised of the validation notice.

C. Quadramed's letter is more closely analogous to the collection letters in Burns, supra, Terran v. Kaplan, 109 F.3d 1428 (9th Cir. 1997), and Vasquez v. Gertler Gertler, Ltd., 987 F. Supp. 652 (N.D.Ill. 1997), which were found not to have overshadowed or contradicted the validation notice. In Terran, the debtor received a collection letter containing the following language: "Please be advised that this office represents MONTGOMERY WARD CREDIT CORP with whom you have an outstanding balance.

Hence, when a § 1692e(10) claim is premised on the same language or theories as a § 1692g(a)(4) claim, the analysis of the § 1692g(a)(4) claim should be dispositive. See Caprio, 709 F.3d at 155 ("Because we have concluded that the District Court committed reversible error by granting judgment on the pleadings as to the § 1692g claim, we must reach the same conclusion with respect to the claim brought under § 1692e(10)."); see also Vasquez v. Gertler & Gertler, Ltd., 987 F. Supp. 652, 659 (N.D. 111. 1997) (wholly resting its finding that defendant did not violate § 1692e on its finding that defendant did not violate § 1692g). Here, Plaintiff argues that the second sentence of Defendant's debt collection letter violates § 1692e(10) because it did not inform her of the need to inform Defendant in writing that "the debt, or any portion thereof, is disputed" in order to effectively dispute the alleged debt and obtain verification of the alleged debt or a copy of the judgment against her. Compl. ¶¶ 16, 22. This claim is premised on the same theory as Plaintiff's § 1692g(a)(4) claim.

Similarly, in Vasquez v. Gertler & Gertler, Ltd., the Northern District of Illinois addressed contentions that a collection letter asking a debtor to contact the collection agency "without delay" induced a waiver of the debtor's rights. 987 F.Supp. 652, 658 (N.D. Ill. 1997). The plaintiff in that case argued that the request for "contact" encouraged unwritten communication that would not be effective to exercise his verification rights. Id.

That said, the courts have not always found language demanding immediate payment to cross the line. See, e.g., Durkin, 406 F.3d at 417 ("[T]he simple act of demanding payment in a collection letter during the validation period does not automatically create an unacceptable level of confusion so as to entitle the plaintiffs to summary judgment."); Gervais v. Riddle Assocs., 363 F. Supp. 2d 345, 353 (D. Conn. 2005) ("[A] collection letter's demand for immediate payment does not, standing alone, violate the FDCPA.") (citing Morgan v. Credit Adjustment Bd., Inc., 999 F. Supp. 803 (E.D. Va. 1998)); Vasquez v. Gertler Gertler, Ltd., 987 F. Supp. 652, 657 (N.D. Ill. 1997) (holding that request for payment without "further delay" did not "demand payment within a shorter period than 30 days"). These cases, however, are distinguishable from the present circumstances.

Thus, the discussion and decision herein applies to Attention's alleged violations under both § 1692e and § 1692g. Vasquez v. Gertler Gertler, Ltd., 987 F. Supp. 652, 658 (N.D. Ill. 1997). Background

Id. at *3. See also Vasquez v. Gertler Gertler, Ltd., 987 F. Supp. 652, 657 (N.D.Ill. 1997) ("While a demand for immediate payment may overshadow a validation notice, the letter does not demand payment immediately or within any time period less than thirty days. Rather, the letter asks for Vasquez's immediate attention, a request that has never been found to violate section 1692g"). Nor must the payment directive be accompanied by a threat to constitute overshadowing.

The District Court determined that HRRG was entitled to judgment on the pleadings because, “[w]hen allegations under 15 U.S.C. § 1692e(10) are based on the same language or theories as allegations under 15 U.S.C. § 1692g, the analysis of the § 1692g claim is usually dispositive.” Caprio, 2012 WL 847486, at *5 (citing Ardino v. Lyons, Doughty & Veldhuis, P.C., No. 11–848, 2011 WL 6257170, at *11–*12 (D.N.J. Dec. 14, 2011); Vasquez v. Gertler & Gertler, Ltd., 987 F.Supp. 652, 659 (N.D.Ill.1997)). Because we have concluded that the District Court committed reversible error by granting judgment on the pleadings as to the § 1692g claim, we must reach the same conclusion with respect to the claim brought under § 1692e(10).

By contrast, statements that request payment or other actions with no time period specified have been found not to contradict the § 1692g notice.Vasquez v.Gertler Gertler, Ltd., 987 F.Supp. 652, 657 (N.D.Ill. 1997) (concluding request for payment without "further delay" did not "demand payment within a period shorter than 30 days."). See also Terran, 109 F.3d at 1434 (finding request for immediate phone call did not contradict printed notice).

CPA because it is merely "used in the context of a general invitation to call about any questions in a separate closing paragraph"); Magana v. Amcol Sys., No. 17-11541, 2018 WL 2723828, at *4 (D.N.J. June 6, 2018) ("One must stretch their imagination past the point of discomfort, and past the point of the least sophisticated debtor, to read the phrase 'please contact' for 'questions' as being equivalent to an invitation to call to dispute, quarrel, or argue over the validity of a claim."); Reizner v. Nat'l Recoveries, Inc., No. 17-2572, 2018 WL 2045992, at *9 (D.N.J. May 2, 2018) (finding that the phrase "[f]or further information, please write or call us at the address or number contained in this notice," did not violate the FDCPA because it "does not expressly state that Plaintiff should call to contest the debt"); see also Terran v. Kaplan, 109 F.3d 1428, 1430 (9th Cir. 1997) (use of "[u]nless an immediate telephone call is made" did not overshadow or contradict validation notice); Vasquez v. Gertler & Gertler, Ltd., 987 F. Supp. 652, 657 (N.D. Ill. 1997) (use of "contact[] me without further delay" did not overshadow or contradict validation notice). Plaintiff's comparison of the disputed phrase here to the language examined in two Third Circuit cases finding FDCPA violations is inapt.