In Vallies v Sky Bank, 591 F 3d 152 (3d Cir. 2009), the sole issue was whether a plaintiff alleging disclosure violations must prove detrimental reliance to recover actual damages under § 1640(a)1 of the Truth in Lending Act (“TILA”). Vallies brought a putative class action after the note to finance his auto purchase failed to itemize his payment for debt cancellation insurance and failed to calculate the same into the finance charge. Id. at 154, 163. The Third Circuit looked to the statutory language and followed persuasive authority from the Sixth, Ninth, Eleventh, Fifth, Eighth, and First Circuits to conclude that detrimental reliance was required. Id. at 155-56. It affirmed the summary judgment for defendant because plaintiff failed to plead and could not prove detrimental reliance. Id. at 164.