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Amicus Brief of the Federal Trade Commission before the Northern District of Ohio, expressing concerns that the proposed class action settlement agreement preliminarily approved by the Court is unfair to consumers and should be rejected. The proposed settlement agreement includes a “Class Release” provision that the FTC argues could deprive over a million consumers of their existing rights to challenge improper judgments entered against them, to defend themselves in ongoing debt collection actions, and to vindicate violations of collections laws in state and federal court by the Defendants. In exchange for losing these substantive rights, under the proposed settlement consumers would only receive a nominal payment, capped at $10, if they filed a claim form. The FTC further argues that the proposed settlement exposes consumers to additional harm because it does not restrict the ability of the Defendants to use or sell class members’ contact and personal bank information disclosed in the claims process.