On February 23rd, the U.S. Court of Appeals for the Second Circuit held that a debt collector can violate the venue provisions of the Federal Debt Collection Practices Act by suing a consumer in a court that lacks power to hear the action, because the consumer does not reside in that city or a town contiguous thereto. Such a suit is therefore not brought in the "judicial district or similar legal entity" in which the consumer resides, as required by the FDCPA. Hess v. Cohen & Slamowitz LLP.