Nancy Finley (plaintiff) owed a debt. Although California’s statute of limitations to collect the debt had run, Dynamic Recovery Solutions LLC (Dynamic) (defendant) was hired to collect Finley’s debt. Finley was represented by counsel at the time. Dynamic was not notified of Finley’s representation, but there was some evidence that Dynamic may have been aware of it. Dynamic sent a collection letter directly to Finley rather than to her attorney. In the letter, Dynamic identified itself as a debt collector, requested payment, and offered to settle Finley’s account under specific terms. Dynamic also phoned Finley approximately nine times. Finley sued Dynamic for violations of the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. § 1692 et seq. Dynamic moved for summary judgment.