On June 8, the U.S. Court of Appeals for the Ninth Circuit held that a debt validation notice does not violate the FDCPA if it only implicitly, rather than expressly, requires a debtor to dispute his or her debt in writing. Riggs v. Prober & Raphael, No. 10-17220, 2012 WL 2054640 (9th Cir. June 8, 2012). In Riggs, a debt collection law firm, in seeking to collect a debt owed to one of its clients, sent a debt validation notice to a debtor which implied that if the debtor wanted to dispute the debt, she would need to do so in writing. The debtor failed to contact the firm and made no payment towards her debt. Instead, after settling an action brought against her by the firm in state court, the debtor filed suit against the firm in federal court, alleging that the firm violated the FDCPA and its California equivalent because it required her to dispute her debt in writing and therefore misrepresented her right to dispute the debt. In affirming the ruling of the district court, the Ninth Circuit acknowledged that the “least sophisticated consumer” could interpret the firm’s debt validation notice to imply that any dispute of the debt must be in writing. Nevertheless, recognizing that the FDCPA itself can be read to imply that a debtor must dispute a debt in writing, the Ninth Circuit held that there is a violation of the FDCPA only where the debt validation notice expressly requires the dispute be in writing.