A recent decision by the Third Circuit Court of Appeals requires that a false statement must be material in order to be actionable under the Fair Debt Collection Practices Act. Jensen v. Pressler & Pressler, and Midland Funding, LLC, Case No. 14-2808 (3rd Cir. 2015). The Court reaffirmed the “least sophisticated debtor” standard as the proper test in which to determine whether a cause of action lies under the FDCPA.