I think this case trumps

[divemedic]

I think I have found a case that beats the Chaudhry case.

Chaudhry v. Gallerizzo, 174 F.3d 394 (4th Cir. 1999)

Take a look at this case and tell me what you think. It is much more recent: (pertinent parts in red)

In the

United States Court of Appeals

For the Seventh Circuit

____________

No. 03-4108

JODI FIELDS,

Plaintiff-Appellant,

v.

WILBER LAW FIRM, P.C., a dissolved corporation, and DONALD L. WILBER and KENNETH WILBER, doing business as WILBER LAW FIRM, P.C., a dissolved corporation,

Defendants-Appellees.

____________

Appeal from the United States District Court

for the Central District of Illinois.

No. 03 C 1079—Michael M. Mihm, Judge.

____________

ARGUED MAY 27, 2004—DECIDED SEPTEMBER 2, 2004

____________

Before FLAUM, Chief Judge, and MANION and KANNE, Circuit Judges.

KANNE, Circuit Judge. On March 16, 2002, Jodi Fields incurred $122.06 in charges at Kruger Animal Hospital in Bloomington, Illinois. Despite signing an agreement promising

to pay the bill at a later time, Fields had not yet paid any of the debt by November of 2002. Kruger hired the Wilber Law Firm to collect the debt. On November 6, a dun2

No. 03-4108 ning letter, signed by Donald Wilber of the Wilber Law Firm (collectively “Wilber”), was sent to Fields; it stated that the “ACCOUNT BALANCE” was $388.54. The account balance reflected the original $122.06, plus interest and service charges assessed pursuant to the contract signed by Fields, plus $250 in attorneys’ fees for the collection of the debt by Wilber. Three more letters followed, each letter including a slightly higher “ACCOUNT BALANCE” to reflect the accumulation of interest. The subsequent letters were sent on December 11, 2002 ($391.34), December 27, 2002 ($392.30), and February 7, 2003 ($395.30). No additional attorneys’ fees were sought in the later letters. Wilber included the $250 in fees pursuant to a clause in the contract that stated: “I understand that if collection action should become necessary for recovery of any monies due under this contract, I agree to pay any and all collection costs and attorney fees.” The collection letters did not itemize the expenses or explain the amount of the debt in any way.

On March 25, 2003, Fields filed an action in federal court, alleging that Wilber violated the Fair Debt Collection Practices Act, 15 U.S.C. §§ 1692, et seq. (“FDCPA”). Specifically,

Fields asserted that the collection letters failed to accurately state the amount of the debt under § 1692g(a)(1), were misleading under § 1692e, and unfairly attempted to collect unauthorized fees under § 1692f(1). The district court dismissed Fields’s FDCPA claims for failure to state a claim and held that $250 in attorneys’ fees was reasonable as a matter of law. For the reasons that follow, we affirm in part and reverse in part.

I. Analysis We review the district court’s decision to dismiss Fields’s

claims de novo, “accepting the well-pleaded allegations in the complaint as true and drawing all reasonable inferences No. 03-4108 3 in favor of the plaintiff.” Marshall-Mosby v. Corporate Receivables, Inc., 205 F.3d 323, 326 (7th Cir. 2000). In deciding whether the collection letters violate the FDCPA, we examine them from the standpoint of an unsophisticated consumer. See Veach v. Sheeks, 316 F.3d 690, 692 (7th Cir. 2003); Bartlett v. Heibl, 128 F.3d 497, 500 (7th Cir. 1997). “This assumes that the debtor is uninformed, naive, or trusting[.]” Veach, 316 F.3d at 693 (internal quotations

omitted). However, an unsophisticated consumer possesses “rudimentary knowledge about the financial world” and is “capable of making basic logical deductions and inferences.” Pettit v. Retrieval Masters Creditors Bureau, Inc., 211 F.3d

1057, 1060 (7th Cir. 2000). A. The Amount of the Debt under 15 U.S.C. § 1692g(a)

Under the FDCPA, “[w]ithin five days after the initial communication with a consumer in connection with the collection of any debt, a debt collector shall . . . send the consumer

a written notice containing—(1) the amount of the debt[.]” 15 U.S.C. § 1692g(a).

Fields first contends that Wilber, by unilaterally determining $250 to be the amount of attorneys’ fees charged, misstated the actual amount of the debt. Fields does not deny that she owes some reasonable attorneys’ fees under the contract. But barring a stipulation to a specific liquidated amount in the original debtor-creditor contract, Fields proposes debt collectors should be required to seek court approval for a specific amount of attorneys’ fees before including them in the account balance.

Essentially, Fields asks us to endorse an approach that would require every debt collector under the FDCPA to go to court every time it sought to enforce a provision in a payment

agreement signed by the debtor that allows reimbursement of attorneys’ fees and collection costs. Plainly stated, the statute does not require such an extraordinary

result. 4 No. 03-4108 Nor, contrary to Fields’s protestations, does our case law. In

Veach, an individual (Veach) who had no contractual relationship with the creditor attempted to prevent the repossession of his debtor-friend’s automobile by sending a check for $350 to the creditor. 316 F.3d at 691. The creditor repossessed the auto despite this payment, and Veach responded by stopping payment on the check. Id. The creditor responded to Veach’s action by hiring an attorney to file suit. The attorney

sent Veach a written notice that listed the remaining principal balance as $1050 (reflecting treble damages under an Indiana statute), “plus reasonable attorney fees as

permitted by law, and costs if allowed by the court.” Id. at 692.

We held that the attorney violated § 1692g(a)(1) by stating the amount of the debt as an estimate of future potential liability in a court action rather than as a statement of the

current amount of the debt. Id. at 692-93. The debt collector “took it upon himself to hold Veach liable for [statutory] penalties that had not yet been awarded, penalties that for

FDCPA purposes should have been separated from the amount of the debt.” Id. at 692. “[T]he ‘amount of the debt’ provision is designed to inform the debtor (who, remember,

has a low level of sophistication) of what the obligation is, not what the final, worst-case scenario could be.” Id. at 693 (emphasis in original).

The case before us today differs significantly from Veach. Here, based on a written, signed contract, Wilber attempted to collect an undisputed debt amount, an undisputed amount in interest, and an amount in attorneys’ fees (incurred in the initiation of Wilber’s collection attempts), disputed for its reasonableness only. Some attorneys’ fees have already been incurred in this case and are contractually owed to Kruger, the hospital that provided unpaid veterinary services to Fields. Whereas in Veach, the attorneys’ fees (along with the treble damages and court costs also included in the dunning

letter) could only be determined in litigation pursuant to a state statute.

No. 03-4108 5 To collect attorneys’ fees from Fields, Wilber necessarily had to specify an amount that it intended to charge (or had already charged) for its services. Fields, of course, could negotiate this payment or contest the reasonableness of the fees through a lawsuit. But when a debtor has contractually agreed to pay attorneys’ fees and collection costs, a debt collector may, without a court’s permission, state those fees and costs and include that amount in the dunning letter. Doing so does not violate the FDCPA. Indeed, refusing to quantify an amount that the debt collector is trying to collect could be construed as falsely stating the amount of debt. See Miller v. McCalla, Raymer, Padrick, Cobb, Nichols, and Clark, L.L.C., 214 F.3d 872, 875-76 (7th Cir. 2000) (letter required the consumer to call a toll-free number to determine the full amount of the debt). The

district court correctly determined that no claim for relief was stated under 15 U.S.C. § 1692g(a).

B. 15 U.S.C. § 1692e and 15 U.S.C. § 1692f

Even if attorneys’ fees are authorized by contract, as in this case, and even if the fees are reasonable, debt collectors must still clearly and fairly communicate information about the amount of the debt to debtors. This includes how the total amount due was determined if the demand for payment includes add-on expenses like attorneys’ fees or collection costs. “A debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of any debt.” 15 U.S.C. § 1692e. As an example of such conduct, § 1692e(2)(A) states that it is a violation to falsely represent “the character, amount, or legal status of any debt[.]” Section 1692f states that “[a] debt collector may not use unfair or unconscionable means to collect or

attempt to collect any debt.”

6 No. 03-4108

We conclude that Fields has made allegations sufficient to state a claim under § 1692e and § 1692f and a dismissal pursuant to Federal Rule of Civil Procedure 12((6) was inappropriate because the letters could conceivably mislead an unsophisticated consumer. In the original dunning letter, Wilber listed an account

balance that exceeded the principal obligation by $266.48. Wilber’s fees were more than double the original obligation, $122.06. Nowhere did Wilber explain that it was seeking

attorneys’ fees of $250. Fields received the initial dunning letter almost eight months after she incurred the charges at the veterinary hospital. An unsophisticated consumer could reasonably wonder why her bill was now $388.54, even assuming she had saved the original contract that specified she could be charged for attorneys’ fees. It would be difficult for such a consumer to understand how a relatively modest fee for services rendered had tripled in size. Cf. Johnson v. Revenue Mgmt. Corp., 169 F.3d 1057, 1060 (7th Cir. 1999) (“Unsophisticated readers may require more explanation than do federal judges; what seems pellucid to a judge, a legally sophisticated reader, may be opaque to someone whose formal education ended after sixth grade.”). Or, an unsophisticated consumer may have lost the bill and forgotten the amount of the debt completely. In this

circumstance, the debtor (or the debtor’s spouse, or someone else paying bills for the debtor) might logically assume that she simply incurred nearly $400 in charges. By leaving the door open for this assumption to be made, Wilber’s letter was misleading because it gave a false impression of the character of the debt. It is unfair to consumers under the

FDCPA to hide the true character of the debt, thereby impairing their ability to knowledgeably assess the validity of the debt. One simple way to comply with § 1692e and § 1692f in this regard would be to itemize the various charges that comprise the total amount of the debt. No. 03-4108 7

The district court agreed that the dunning letter in this case was facially misleading. But we are forced to disagree with the district court’s determination that the letters’ misleading nature was irrelevant as a matter of law because Fields could reference the contract from Kruger Animal Hospital or because she could telephone Wilber and ask for

an explanation.

As we noted above, even if she saved her contract from nearly eight months earlier, the unsophisticated consumer would not necessarily understand that Wilber was seeking

$250 in attorneys’ fees, an amount allowed, but not specified, by the contract. Furthermore, in Miller, 214 F.3d at 875-76, we rejected the proposition that a debt collector could provide incomplete information in a dunning letter so long as it provided a telephone number for the debtor to call. “It is notorious that trying to get through to an 800 number is often a vexing and protracted undertaking, and

anyway, unless the number is recorded, to authorize debt collectors to comply orally would be an invitation to just the sort of fraudulent and coercive tactics in debt collection that the Act aimed (rightly or wrongly) to put an end to.” Miller, 214 F.3d at 875. Wilber did not satisfy all of its FDCPA obligations by including a telephone number on the dunning

letter.

II. Conclusion

For the foregoing reasons, we AFFIRM the district court’s determination that Fields did not state a claim for relief under 15 U.S.C. § 1692g(a). We REVERSE the district court’s

dismissal of Fields’s remaining claims under 15 U.S.C. §§ 1692e and 1692f, and REMAND for proceedings consistent with this opinion.

8 No. 03-4108

A true Copy:

Teste:

________________________________

Clerk of the United States Court of

Appeals for the Seventh Circuit

USCA-02-C-0072—9-2-04

[Guest]

Dive

What a swank little bit of law you have come across here.

I love it!!!

[Chancy949]

Very Interesting

[divemedic]

The best part-

"One simple way to comply with § 1692e and

§ 1692f in this regard would be to itemize the various

charges that comprise the total amount of the debt. "

[Chancy949]

[ZphisticatedLady]

Divemedic,

So I'm confused, that case was long, but when a CA responds with Chaundry, do you reply back to them with this case? and demand they validate?

[bf9868539]

I just received a ca letter stating this case. They have not validated, claim this says they do not have too. what response should I do

[Recovering Attorney]

Tell them that Chaundry is not the law of the land. Remind them that the FTC's Wollman letter ( you can get a copy at the opinions page at the FTC) requires them to give you detailed information on the alleged debt. Tell them to do so in 30 days or you will consider them in violation. Remind them that since you dispute the debt, and they know the debt is disputed, they should not tell anyone else about this debt or you will sue for that, too.

Copy the FTC and your State AG on the letter.

[codename_fortyseven]

Ya gotta love these CA's that demand letters be signed or say they don't have to validate debts. gotta love it!

[Ripped Off]

Ya gotta love these CA's that demand letters be signed or say they don't have to validate debts

They have never sent me a letter that had a signature on it!!!

[Crabjoe]

What the heck is this case? I read it but not being a lawyer, I don't see how it allows a collection agency to not validate a debt under FDCPA Section 809.

The reason I'm looking into this thing is because I disputed a debt requesting validation and Sherman, Merchants, Alegis, or whatever they are calling themselves today sent back what looked to be some kind of bogus affidavit referencing this case saying all they had to do was send me a letter saying the debt was legit and not product any info on this debt.

I'm really pissed at them as I do not believe this debt is mine as I've never had service with this Southwesternbell MOB and they will not provide any documentation.

Please let me know what you think of my response below. Also does anyone have an address to the FTC where I can request them to send me an opinion on the Chaudhry v. Gallerizzo case and how it would allow a debt collector to circumvent FDCPA Section 809?

Thanks!

===========================

Alegis Group K.P

15 South Main St, Suite 600

Greenville, SC 29601.

May 3, 2005

To Whom It May Concern:

This letter is in response to your so called verification letter where you sent me a reference to Chaudhry v. Gallerizzo saying that just sending me a letter saying I owe the debt was sufficient for account verification.

Based on the opinion you are referencing in that case, I do not see how that pertains to you trying to collect a debt that you are not willing to validate. That opinion had nothing to do with debt validation. It was an argument over attorney fees which were determined to be "work product".

As that is not valid under the Fair Debt Collection Practices Act (FDCPA) section 809. Validation of debts [15 USC 1692g.], I am again requesting you to send me validation within 30 days as I do not believe you have the correct person, nor have you sent me any of the information as FDCPA requires once requested.

Because it seems you are not familiar with the FDCPA Section 809, I’ve enclosed a copy of it, in addition to two opinion letters from the FTC (Wollman and Krisor Letters), and my original form I enclosed with what I am requesting.

In addition, to the best of my knowledge, the Statue of Limitations here in the State of Maryland is three years on open accounts and written contracts. At this point in time, I have to assume you are beyond these limits as you state in your last letter that you had purchased the debt in 2001 and you have not provided any documentation to show that the debt is mine or even real. Based on this alone, you are beyond the timeframe of when a party here in Maryland is liable.

As you should be aware, your company’s original correspondence did state that one had the right to dispute or request validation if done in writing within 30 days. Based on that alone, you should be dropping this collection activity, as you do not seem to be able to validate the debt or even show that it is within the Statute of Limitations.

I request that you cease and desist all collection activity against me unless you are able to validate the debt under FDCPA Section 809. Again, you now have 30 days to provide validation. If you see that the validation documentation you are able to send shows that the debt is may not be mine, past the statute of Limitations, or you do not have the documentation required under FDCPA, please cease all activities against me.

Sincerely,

XXXXXXXXXXX

Cc FTC

Cc Maryland Attorney General

[bf9868539]

I sent a letter very similiar to the one above, and the wollman letter and refernce to a case(can not think of now) and have not heard back from the ca

[divemedic]

You can no longer get opinions from the FTC. They no longer do that.

[devil21]

FTC opinions are not held routinely as evidence either.

[admin]

FTC opinions are not held routinely as evidence either.

I wondered about that.

[RealtorKen]

FTC opinions are not held routinely as evidence either.

I wondered about that.

However there is sufficient case law saying they can be used IF your state or district does not have sufficient caselaw/state laws that mirror.

However they still should not be sole proof

[Ardellw]

So what is the verdict on EXACTLY how to respond to these people? I just got one of those in the mail today.

[Jazkal]

So what is the verdict on EXACTLY how to respond to these people? I just got one of those in the mail today.

That letter in this thread is a good starting place, IMO. Take that, modify it to meet your needs, I'd even add something referencing the case law in the first post, with some quotes from it (the good parts that were highlighted in red).

I threw this togeather, it's a very rough draft, modify it to fit your needs.

[YOUR NAME][YOUR ADDRESS][DATE] Certified Mail # [CMRRR][CAOC NAME][CAOC ADDRESS]RE: Account #: [CAOC ACCT] To [CAOC NAME],This letter is in response to your so called verification; a letter where you referenced Chaudhry v. Gallerizzo, saying that just sending me a letter saying I owe the debt was sufficient for account verification. Based on the courts opinion which you referenced in that case, I do not see how that pertains to you trying to collect a debt that you are not willing to validate. That opinion had nothing to do with debt validation. It was an argument over attorney fees which were determined to be "work product". As that is not valid under the Fair Debt Collection Practices Act (FDCPA) section 809. Validation of debts [15 USC 1692g.], I am again requesting that you send me validation of this alleged debt before you continue with your collection activities. I would suggest you lookup and review the case of Fields v. Wilber. This case law does concern the topic at hand and explains what is required to validate a disputed debt. I’ve enclosed two excerpt from the case that will help you:Fields v. Wilber Law Firm, P.C., 383 F.3d 562, 564-66 (7th Cir. 2004) “… debt collectors must still clearly and fairly communicate information about the amount of the debt to debtors. This includes how the total amount due was determined …”“…simple way to comply with § 1692e and § 1692f in this regard would be to itemize the various charges that comprise the total amount of the debt.”I request that you Cease and Desist all collection activity on this alleged debt unless you are able to validate the debt under FDCPA Section 809. Best Regards, [YOUR NAME]

[Ardellw]

Thank you sooooooo much!!

[Anonymous]

Tell them that Chaundry is not the law of the land. Remind them that the FTC's Wollman letter ( you can get a copy at the opinions page at the FTC) requires them to give you detailed information on the alleged debt. Tell them to do so in 30 days or you will consider them in violation. Remind them that since you dispute the debt, and they know the debt is disputed, they should not tell anyone else about this debt or you will sue for that, too.

Copy the FTC and your State AG on the letter.

Recovering from what? A wasted legal education?

While it is true that an appeals opinion may not be "the law of the land" if it conflicts with Supreme Court precedent, it certainly IS the law if you happen to be in that circuit (and persuasive in others minus a spilt awaiting SC cert.).

It may be possible to excuse non-attorneys offering "legal advice" that is not in accord with the law, but if you were ever licensed, shame on you. No wonder people hate lawyers.

Look where executive branch opinions on the meaning of laws has left us (as a country, NOT as crusading debtors) lately. If you want to be on solid ground, better to listen to Justice Posner and the like than some b-crat who is heading out the revolving door to MBNA, Citibank, etc.

If you just have a cute name and are not an attorney, let me apologize in advance.

law student, $80k in hole.

PS-i did not Shepardize the Chaudry case (you can pay lexis for that), so it MAY be worthwhile to check for differences of opinions in your circuit.

[divemedic]

The Chaudhry case concerns protected work product, and the cite used by CA's is taken out of context. Chaudhry is an old case, and there have been others since then that do a better job of defining validation.

Schlosser v. Fairbanks Capital Corp., 323 F.3d 534 (7th Cir. 2003)

Nance v. Lawrence Friedman P.C., 2000 WL 1230462 (N.D. Ill. Aug. 28, 2000). The court recognized that the plaintiff may prevail if the [verification] letter was ‘‘confusing’’: ‘‘Confusion is an issue of fact, not a question of law. On summary judgment, this meant that the plaintiffs must offer some evidence to create a triable issue as to whether the letter was likely to confuse the unsophisticated debtor.’’

You don't work for a CA by any chance, do you? Your only posts so far have been rather inflammatory.

[DocDon]

Recovering from what? A wasted legal education?

It may be possible to excuse non-attorneys offering "legal advice" that is not in accord with the law, but if you were ever licensed, shame on you. No wonder people hate lawyers.

Why does there always seem to be issues with law students attacking our member attorneys?

If I ever talked like that to anyone on the FD while I was a Probie, they would have hoisted me up the flagpole.

Let me direct you to our law:

POSTING 101: NEW MEMBERS PLEASE START HERE

Public personal attacks, flaming, name calling, and trolling are not allowed. This is not an AOL chatroom. We are all adults here. Bickering should be done via PM

http://debt-consolidation-credit-repair-service.com/phpBB2/viewtopic.php?t=39982

Thanks.

[Anonymous]

You don't work for a CA by any chance, do you? Your only posts so far have been rather inflammatory.

I tell you what, you read this e-mail with your complete attention and decide for yourself.

1. "inflammatory"? Are you serious? If we are all adults here, SURELY we can be as zealous as advocates in a 10th grade debate class, no? Since you sought out my two "posts" and found them to be beyond the realm of propriety, I would suggest that you hire proper representation before pursuing an appeal in our federal courts. It is not nice to see a grown man cry when getting backed into a corner in oral argument.

2. So you think that the reference to "debt collectors" not needing to have reems of paper documents (including original contracts) itemizing every charge made on an account is just dicta in Chaudhry? Is that why they cited two cases in different circuits (one of which was denied cert by no less than S.C. on the issue)? I would suggest that the bass-ackwards respect you give holdings of our federal courts and FTC opinions requires a 180 degree swing, otherwise your clients could be in for a hell of a ride. (if you DO have clients..or are you just a professional debtor?)

3. The Schlosser v. Fairbanks Capital Corp case is too far off the original point (level of validation requirred) made in this thread to even comment on.

4. I am not sure why you quote the last case, unless you just cut and paste these things willy nilly and chose the wrong one which, considering the informality of this forum, is totally excusable. Or maybe you were just looking for something we agree on. If so, you were spot on.

Lastly, anyone who TRULY violates the FDCPA SHOULD be sued (and seems usually is at some point). I do not have a problem with that. I also do not have a problem with people going after money that is owed to them for a bargained for exchange. Where do you REALLY think this country would be without credit?

Our legal system, not great, but still the greatest, does not allow debtor prisons (anymore anyway). Because of this, persons who can not pay, need not worry. They only need show up to claim exemptons, and then go back home. What is the big draw on attempting to avoid the repayment of your debts simply becasue a well-meaning law (that was DEARLY needed, no doubt) allows you to file strike suits or extort money out of people who, like you, are just trying to make ends meet.

If you CAN pay the money you owe, and simply refuse to do it, the law has ways to force you to, against your will. Who requires that it rise to that level? Creditors? Debt-buyers?

What do you think happens when creditors "write-off" these debts? Do you not think that it impacts interest rates for well-intentioned debtors who may not yet have great credit? Do you not realize that it increases the tax responsibility for those of us that have to go to work everyday?

I have no problem with most of you out here who are trying to help people who can not understand their rights and can not afford an attorney.

What is inexcusable, and adversaries from both sides should agree with this, is some "lawyer" feeding dangerous "legal advice" to people who may try to go into battle in this area. If/when they do and if/when they get slapped with sanction for bad-faith litigation/harassment, who is going to pay the bill? You? Mr. "screen name" on debt-consolidation-credit-blah-blah.com?

Or is that the game, you guys are out here convincing debtors who have something to lose (which now includes good amount of interest) that they should hire you to get help professionally welching on their obligations. So which side is more to blame? Which side comes down on the right side as far as policy is concerned? Societal policy? Economic (not pocketbook economics here friedman, economics as in pecuniary externalities and rent-seeking).

For the record, I am doing a research paper on FDCPA rulings in 7th circ. I do find it interesting in that the more people try to avoid their debts, the more it creates a very good opportunity for personal wealth on both sides. (although it does little to help persons who are upside down financially, which was the intention of the act)

A. collection side: collect on the original debt (even IF it has been purchased for 5 cents per dollar, it is still valid for orig. amount), and

B. Those looking to milk robots who take their orders from Madison avenue of even MORE money.

This, unfortunately, is "industry" in this great land of ours anymore. We should all be ashamed for allowing this to happen, but it has. Let the chips fall where they may.

As for which side I would trend toward IF i enter this god-awful racket? Which-ever pays the most, of course....I NEED that Plasma screen man!

Thanks for the chance to chatter, hpe i did not hurt your feelings again.

Do not answer this for my sake as finals approach, and after that it will be 8-12 (both am) for a month or two to study for the bar.

[Anonymous]

by the way, as a "newbie" (as i am guessing is a popular term out here) I have no idea what a FD or a probie are. Unless, of course, probie refers to a sexual toy or role that you happen to be fond of and, although very interesting to me if you are of the Female gender, is totally off the topic of this conversation.

You should actually have rules against persons holding themselves out as officers of our courts (lawyers) who give crap "legal" advice. The people who really come here for assisstance (versus the community) would be much better served.

[Sinuous]

Wow........for someone who claims to have a graduate level education you betray an ignorance unmatched. Even an individual with rudimentary knowledge of professions would be able to deduce that "FD" means Fire Department, and "probie" refers to the probationary period all FD trainees must pass to become full-fledged firemen. Instead, your anger at your own ignorance causes you to regress into childish personal attacks and sexual degradation. The result is that you are so transparent, everyone can see through your carefully crafted internet facade. It is painfully obvious that you have never had to work a day in your life, living a sheltered existence in a well-to-do household where greed was emphasized as an endearing trait. I'll let you in on a little secret: if mommy and daddy paid for your education, YOU are not $80K in debt. To top it off, you write a freaking book of a post attacking each topic of contention point by point in bullet format.

You seem to possess the most basic glimmer of intellect, so take my advice and do a little soul-searching into what really matters in life.