In Echlin v. PeaceHealth, 887 F. 3d 967 (9th Cir. 2018), the court of appeals affirmed the district court's grant of summary judgment against a former patient who filed a putative class action against a hospital and purported debt collection agency alleging violations of the Fair Debt Collection Practices Act (FDCPA). After a patient of PeaceHealth Southwest Medical Center ignored multiple requests for payment of her medical bill, PeaceHealth referred her delinquent account to Computer Credit Inc. (CCI). The plaintiff argued that CCI fell within FDCPA's prohibition against so-called "flat-rating," whereby a third party (usually for a flat rate) sells form letters to a creditor "which create the false impression that someone (usually a collection agency) besides the actual creditor is 'participating' in collecting the debt." The court of appeals rejected the plaintiff's argument based on these facts: 1) CCI independently screened accounts for barriers to collection; 2) CCI alone drafted and mailed the collection letters, without input from PeaceHealth; 3) the letters invited debtors to contact CCI by mail or phone, and CCI trained its personnel to handle such inquiries; 4) CCI in fact received approximately 500 calls a week from debtors of its various clients and received several hundred pieces of mail from PeaceHealth debtors; 5) in their conversations with debtors, CCI staff provided a variety of information about their debts and how to repay them; 6) CCI maintained a website where PeaceHealth debtors could access individualized information about their debts and submit documents to CCI; and 7) CCI sometimes received and forwarded to PeaceHealth payments it received from debtors. The court of appeals also agreed with the district court that the complaint did not give CCI fair notice of a claim that it violated FDCPA's prohibition against threatening to take any action that could not legally be taken or that was not intended to be taken.