Barclift v. Keystone Credit Servs.

6 Citing cases

  1. Nuamah-Williams v. Frontline Asset Strategies, LLC

    Civ. 2:21-cv-15440 (WJM) (D.N.J. Feb. 2, 2023)   Cited 2 times

    ....โ€ Foley v. Medicredit, Inc., No. 21-19764, 2022 WL 3020129, at *3 (D.N.J. July 29, 2022) (citing Hamza v. United Cont'l Holdings, LLC, No. 19-8971, 2021 WL 3206814, at *10 (D.N.J. July 29, 2021)). The โ€œ'invasion of privacy requires publicity in the broad, general sense of the word โ€˜public.'โ€ Barclift v. Keystone Credit Servs., LLC, 585 F.Supp.3d 748, 758-59 (E.D. Pa. 2022) (citing Tureen v. Equifax, Inc., 571 F.2d 411, 418 (8th Cir. 1978)).

  2. Moore v. Merchants & Med. Credit Corp.

    Civil Action 21-cv-1724 (M.D. Pa. Sep. 25, 2023)

    District courts in this circuit have reasoned similarly. Barclift v. Keystone Credit Servs., LLC, 585 F.Supp.3d 748, 758 (E.D. Pa. 2022) concluded that a plaintiff alleging a violation identical to that alleged here did not have standing because โ€œthere was no publicity.

  3. Rabinowitz v. Alltran Fin.

    Civ. Action 21-12756 (D.N.J. Oct. 25, 2022)

    have addressed standing in the context of the letter vendor theory. See, e.g., Madlinger, No. 21-00154, 2022 U.S. Dist. LEXIS 109328, Pagan v. Convergent Outsourcing, Inc., No. 21-12130, 2022 U.S. Dist. LEXIS 71428 (D.N.J. Mar. 30, 2022), Rohl v. Prof'l Fin. Co., No. 21-17507, 2022 U.S. Dist. LEXIS 96934 (D.N.J. May 31, 2022), Foley v. Medicredit, Inc., No. 21-19764, 2022 U.S. Dist. LEXIS 135422 (D.N.J. July 29, 2022), Barclift v. Keystone Credit Servs., LLC, 585 F.Supp.3d 748 (E.D. Pa. 2022). A vast majority of courts, both in this District and nationwide, have concluded that the letter vendor theory is not, alone, sufficient to confer Article III standing.

  4. In re BPS Direct, LLC

    705 F. Supp. 3d 333 (E.D. Pa. 2023)   Cited 3 times

    Judge Leeson reasoned because Ms. Barclift did not allege Keystone shared her information with a larger group of people, her alleged injury does not bear a close relationship to the tort.Barclift v. Keystone Credit Servs., LLC, 585 F. Supp. 3d 748 (E.D. Pa. 2022).

  5. JTH TAX LLC v. Foster

    691 F. Supp. 3d 691 (W.D. Pa. 2023)   Cited 2 times

    The Court will address the subject-matter jurisdiction challenge before turning to the merits-based arguments. See Barclift v. Keystone Credit Servs., LLC, 585 F. Supp. 3d 748, 751-52 (E.D. Pa. 2022) (citing Hollingsworth v. Perry, 570 U.S. 693, 704-05, 133 S.Ct. 2652, 186 L.Ed.2d 768 (2013)) ("Before this Court can address the merits of any case, it must have subject-matter jurisdiction over the plaintiff's claims.").

  6. Steichen v. 1223 Spring St. Owners Ass'n

    No. 82407-4-I (Wash. Ct. App. Oct. 23, 2023)   Cited 2 times

    Federal courts have extended this holding to the FDCPA. Barclift v. Keystone Credit Servs., LLC, 585 F.Supp.3d 748, 760 (E.D. Penn. 2022) (dismissing claim for violating 15 U.S.C. ยง 1692c(b) because bare procedural violation of the FDCPA alone does not establish concrete harm). In Dolan v. Sentry Credit, Inc., the U.S. District Court explained that Congress's intent, in passing the FDCPA, was to protect the consumer by eliminating abusive debt collection practices, however, Congress did not intend "to create hypertechnical protections."