In Hart v. Credit Service Company, plaintiff alleged that defendant violated the FDCPA by attempting to collect a debt that was not owed because the purchased item was returned in exchange for full settlement of the debt, as evidenced by the issuance of a 1099-C by the creditor.  The parties filed cross motions for summary judgment.  The court entered summary judgment for defendant, finding that plaintiff had offered no evidence that returning the purchased goods settled the account,  and that the issuance of a 1099-C does not constitute notice that a debt is being forgiven.  The court found that issuing a 1099-C, standing alone, does not equal extinguishment of the debt.

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