Court holds that leaving a message at your place of employment is not a "communication."

Under the Fair Debt Collection Practices Act, a debt collector's actions in "communicating" with a debtor are strictly limited.  In Brown v. Van Ru Credit Corp., the plaintiff argued that the defendant violated the FDCPA when it left a voice message at the debtor's workplace requesting a return of the call.

The Court held that simply leaving a voice message requesting a return of the call is not a "communication" under the FDCPA because a "communication must convey...information regarding a debt directly or indirectly to any person through ay medium..." and such a message contains no information.