In Donohue v Quick Collect, No 09-35183, 2010 US App LEXIS 772, at *10, *17-19 (9th Cir. Jan. 13, 2010), the Ninth Circuit concluded that: (1) a debt-collection complaint served directly upon a consumer is a communication subject to the Fair Debt Collection Practices Act (“FDCPA”); and (2) technical, non-material inaccuracies within covered communications are not actionable under the FDCPA. Donohue filed a putative class action against Quick Collect, alleging FDCPA violations when its debt-collection complaint and demand letter charged a usurious annual rate above 12%, the maximum under Washington law. Donohue also claimed that Quick Collect violated the prohibition against the use of false or misleading statements via “misrepresenting the amount of interest”—that is, the debtcollection complaint incorrectly stated that $32.89 was interest of 12% per annum on the $270.99 principal. Id. at *2-3. The Ninth Circuit affirmed the grant of summary judgment for defendant, finding that it did not charge a usurious rate, and that the complaint’s technical failure to breakdown both interest and pre-assignment finance charges was not materially false. Id. at *9, *18.