Ever receive a debt collection letter disguised as a "Free Credit Card Offer?"  If so, your rights were violated. While it might appear obvious, but initial written communications by debt collectors to consumers must be transmitted in a way so as not to mislead or deceive the least sophisticated consumer. Debt collectors have taken a new approach in their attempts to deceive and overshadow their statutory obligations to provide notice of certain rights to consumers. In Voris v. Resurgent Capital Servs., L.P., 494 F.Supp.2d 1156 (S.D. Cal. 2007), Hyde & Swigart asserted that the sending of an initial collection letter disguised as junk mail violated both the Fair Debt Collection Practices Act, 15 U.S.C. §§ 1692 et seq. (“FDCPA”) and the Rosenthal Fair Debt Collection Practices Act, California Civil Code §§ 1788-1788.32 ("Rosenthal Act"). The Court agreed and found that debt collectors could not send the initial written communication in envelopes with the language “Pre-approved” written on the outside. This language, taken together with the form and content of the letter included, did not amount to benign language, but did in fact violate 15 U.S.C. § 1692f(8) by “telling only half the story” and actively misleading the consumer into believing that the collection letter was merely junk mail.