According to consumers, CRA used language in its initial collection letters that was confusing and deceptive. Federal law requires that all collection services include a notice in their initial collection letters that informs consumers of their right to investigate the validity of a debt within 30 days. Although CRA’s letter contained this notice, consumers allege that other language in the letter overshadowed the notice and rendered it ineffective. Specifically, the letters requested immediate attention by remitting payment. Consumers allege that by demanding immediate attention and payment, they were unable to determine if they were given 30 days to investigate the validity of the debt, or if they were required to pay immediately. Additionally, the letters were allegedly "signed" by Richard Lyons. According to consumers, there is no viable evidence to suggest that a Richard Lyons reviewed their debt or that Richard Lyons is even employed by CRA. However, consumers claim this “signature” is meant to convey to them that the debt had been reviewed by an actual person. According to consumers, CRA also routinely charges allegedly illegal fees for returned checks. Finally, even after repeated attempts to dispute the validity of the debts, many consumers claim that CRA never provided them with validation.

Under the Fair Debt Collection Practices Act, any unfair, misleading or intimidating language is forbidden in collection letters or other forms of communication. The consumers allege that the language used by CRA fulfills this standard. They claim that CRA's language overshadows and renders ineffective the 30 day notice of disputing the validity of the debt. They claim that CRA's use of a signature that is allegedly bogus conveys a false and misleading impression that an actual person has reviewed their account, when in fact the letters are "form" type and mass mailed. Finally, consumers claim that CRA typically ignores all attempts to dispute the validity of the debt and continues with coercive efforts designed to elicit immediate payment. According to consumers the potential class is quite numerous, numbering in the thousands, and perhaps tens of thousands.