Dan Ryan and David Katz won a 12(b)(6) dismissal motion in the U.S. District Court for the Northern District of New York. Plaintiff claimed various violations of the Fair Debt Collection Practices Act. Dan and Dave successfully argued that the client, who owned the debt, was not a debt collector under the FDCPA relying on Henson v. Santander Consumer USA, Inc., 137 S. Ct. 1718 (2017).