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We have many cases where CA's tell consumers the DV has to be signed. Here is case law that states it doesn't even have to be in writing:

Spearman v. Tom Wood Pontiac-GMC, Inc., 2002 WL 31854892 (S.D. Ind. Nov. 4, 2002). Collector’s incorrect § 1692g validation disclosure that any dispute must be in writing was a false representation in violation of § 1692e.

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The 2nd Circuit have opined in In re RMA 208 FRD 498 ( 2002)

Just remember that an oral dispute does not necessarily trigger the obligation to validate, even if made w/in the first 30 days.

There is a decision, however, that supports the theory that since an oral dispute gives the CA notice of a dispute, it should do something to satisfy itself that the debt is valid. In re Sanchez 173 FSupp2nd 1029

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