Resolving tension between New York and federal law, the U.S. Court of Appeals for the Second Circuit has ruled that a debtor must show that a debt collector's alleged false representation was material for it to be a “false, deceptive, or misleading representation” in violation of the Fair Debt Collection Practices Act . In applying a materiality standard to alleged violations of FDCPA Section 1692e, the Second Circuit joined the U.S. Courts of Appeal for the Third, Fourth, Sixth, Seventh, and Ninth Circuits.