Michael Bloom v. I.C. Sys., Inc., a Minnesota Corp., 972 F.2d 1067 (9th Cir. 1992). · Go Syfert
Michael Bloom v. I.C. Sys., Inc., a Minnesota Corp., 972 F.2d 1067 (9th Cir. 1992). Cases Citing This Book View Copy Cite
165 citation events (134 in the last 25 years) across 46 distinct courts.
Strongest positive: Adewale Eniola Tawose v. Matthew L. Winton, et al. (okwd, 2026-02-09)
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1993 2009 2026
Under fire — who is questioning this case
Citations from separate opinions of courts that could overrule this case. This is a warning signal, not a treatment change. The flag color above is unaffected.
Dissent Aspen Skiing Co. v. Cherrett (In Re Cherrett) (2017)
“Sys., Inc., 972 F.2d 1067, 1069 (9th Cir. 1992), Crucially, “[c]redit extensions by a company to its employees” aie “consumer-purpose” loans under the regulations “if the loans are used for personal purposes.” Id. pt. 226, supp.”
Concurrence James R. and Jamila J. Fleet v. Webber Springs Owners Assoc. (2015)
“Sys., Inc., 972 F.2d 1067, 1068 (9th Cir.1992) (holding that the FDCPA applies only to “consumer debts” incurred “primarily for personal, family, or household purposes”); Nance v. Petty, Livingston, Dawson, & Devening, 881 F.Supp. 223, 225 (W.D.Va.1994) (refusing to find homeowners association fee a “debt” under FDCPA inasmuch it was a “nonconsumer” debt).”
Top citers, strongest first. 50 distinct citers. How cited ↗
cited Cited as authority (rule) Adewale Eniola Tawose v. Matthew L. Winton, et al.
W.D. Okla. · 2026 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992)).
discussed Cited as authority (rule) Shahadi v. Navy Federal Credit Union (2×)
D. Ariz. · 2025 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992).
discussed Cited as authority (rule) Complot v. Citibank NA (2×) also: Cited "see"
D. Ariz. · 2025 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992).
discussed Cited as authority (rule) (PS) Wilson v. Experian Information Solutions, Inc.
E.D. Cal. · 2025 · confidence medium
Sys. 7 Inc., 972 F.2d 1067, 1068-69 (9th Cir. 1992) (explaining that the FDCPA applies only to debts 8 incurred for personal, family or household purposes rather than business or commercial reasons). 9 Here, plaintiff simply says that she “disputed a $600 collection account” but does not 10 describe the nature of the account.
discussed Cited as authority (rule) (PS) Robinson v. Carmax Auto Finance, LLC
E.D. Cal. · 2025 · confidence medium
Inc., 972 F.2d 1067, 1068-69 (9th Cir. 1992) (explaining that the 13 FDCPA applies only to debts incurred for personal, family or household purposes rather 14 than business or commercial reasons).
cited Cited as authority (rule) Tsang v. Porter McGuire Kiakona, LLP
D. Haw. · 2025 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir. 1992); and then citing Slenk, 236 F.3d at 1075 ).
cited Cited as authority (rule) Burns v. LVNV Funding LLC
D. Or. · 2024 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992).
discussed Cited as authority (rule) Targownik v. Sohmer (2×) also: Cited "see, e.g."
E.D.N.Y · 2024 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992))), aff’d, 466 F. App’x 20 (2d Cir. 2012); see also Nicolaides v. Divine & Serv., Ltd., 382 F. Supp. 3d 251, 255 (E.D.N.Y. 2019) (“[T]o determine whether the transaction was primarily consumer or commercial in nature, courts typically ‘examine the transaction as a whole,’ paying particular attention to ‘the purpose for which the credit was extended.’” (quoting Bloom, 972 F.2d at 1068 )).
discussed Cited as authority (rule) Merrill Lynch, Pierce, Fenner & Smith Incorporated v. Sohmer (2×) also: Cited "see, e.g."
E.D.N.Y · 2024 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992))), aff’d, 466 F. App’x 20 (2d Cir. 2012); see also Nicolaides v. Divine & Serv., Ltd., 382 F. Supp. 3d 251, 255 (E.D.N.Y. 2019) (“[T]o determine whether the transaction was primarily consumer or commercial in nature, courts typically ‘examine the transaction as a whole,’ paying particular attention to ‘the purpose for which the credit was extended.’” (quoting Bloom, 972 F.2d at 1068 )).
cited Cited as authority (rule) Lombard Flats LLC v. JP Morgan Chase Bank N.A.
N.D. Cal. · 2024 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992) (cleaned up).
discussed Cited as authority (rule) Northwest Investment Holdings, LLC v. Civic Real Estate Holdings III, LLC (2×)
D. Or. · 2024 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992).
cited Cited as authority (rule) Rosa v. Mandarich Law Group LLP
S.D.N.Y. · 2024 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992) (quoting Tower v. Moss, 625 F.2d 1161, 1166 (5th Cir. 1980)).
cited Cited as authority (rule) Bankers Healthcare Group, LLC v. TCEX, LLC
N.D.N.Y. · 2024 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992)).
cited Cited as authority (rule) Lombard Flats LLC v. JP Morgan Chase Bank N.A.
N.D. Cal. · 2023 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 23 1992) (cleaned up).
cited Cited as authority (rule) Poffenbarger v. Equifax
D. Alaska · 2023 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir. 1992) (emphasis omitted) (quoting 15 U.S.C. § 1681h(e)).
cited Cited as authority (rule) Poffenbarger v. Key Bank Corporation, Keycorp
D. Alaska · 2023 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir. 1992) (emphasis omitted) (quoting 15 U.S.C. § 1681h(e)).
cited Cited as authority (rule) Maxine Gilliam v. Joel Levine
9th Cir. · 2023 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992)).
cited Cited as authority (rule) Bostwick v. SN Servicing Corporation
N.D. Cal. · 2023 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 12 1992) (cleaned up).
cited Cited as authority (rule) Lewis v. Sole Law, PLLC
E.D. Mich. · 2022 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992)); In re Pasley, 596 B.R. 577, 584 (Bankr.
cited Cited as authority (rule) Chattin v. Ideal Business Partners, Inc.
D. Mont. · 2022 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992)).
cited Cited as authority (rule) Schweitzer v. Melane
M.D. La. · 2022 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir. 1992); Thornton v. Equifax, Inc., 619 F.2d 700, 703 (8th Cir. 1980)).
discussed Cited as authority (rule) Curtis Glawe v. Carpenter Hazlewood (2×) also: Cited "see"
9th Cir. · 2021 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992).
discussed Cited as authority (rule) Ergas v. Eastpoint Recovery Group, Inc.
W.D.N.Y. · 2021 · confidence medium
System, Inc., 972 F.2d 1067, 1068 (9th Cir. 1992) (underlining in original)), and “‘examine the transaction as a whole,’” id., as well as “‘the consumer’s purpose.’” Id. (quoting Ernst v. Berson Associates, Ltd., 1994 U.S.Dist.
discussed Cited as authority (rule) Blackmon v. Ad Astra Recovery Services, Inc.
S.D. Cal. · 2021 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir.1992) (finding no “false” representation when 21 the debt collector requested further written verification that no debt was owed and 22 23 24 3 In her opposition brief, Blackmon alleges that during the call, “[AARS] requested Ms. Blackmon to 25 resolve the account which is an attempt to collect payment.” [Doc.
cited Cited as authority (rule) Norton v. LVNV Funding, LLC
N.D. Cal. · 2020 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th 6 Cir. 1992).
discussed Cited as authority (rule) Denicolo v. Viking Client Services, Inc. (2×) also: Cited "see, e.g."
N.D. Cal. · 2020 · confidence medium
System, Inc., 972 F.2d 1067, 1075 (9th Cir. 1992.)).
discussed Cited as authority (rule) Purnell v. Equifax Inc.
E.D. Cal. · 2020 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir.1992) 17 (finding that 15 U.S.C. § 1681h(e) preempts “state common law defamation claims”). 18 Here, the Court is persuaded that Plaintiff’s common law causes of action are preempted 19 under the FCRA because Plaintiff’s allegations do not demonstrate or otherwise suggest that any 20 of the defendants acted with malice or a willful intent to injure.
discussed Cited as authority (rule) Meza v. Experian Information Solutions, Inc.
E.D. Cal. · 2019 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir.1992) (finding that 15 U.S.C. § 9 1681h(e) preempts “state common law defamation claims”); see also, Xiong v. Equifax Info. 10 Servs., LLC, 2005 WL 8154297 , at *5 (N.D.Ga.
cited Cited as authority (rule) Harper v. Weltman, Weinberg & Reis Co., L.P.A.
Ohio Ct. App. · 2019 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir.1992) (holding that the FDCPA applies only to “consumer debts” incurred “primarily for personal, family, or household purposes”).
cited Cited as authority (rule) Noe v. Chastain
W.D. Mo. · 2019 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992)).
discussed Cited as authority (rule) Micks v. Gurstel Law Firm, P.C.
D. Me. · 2019 · confidence medium
Bloom , 972 F.2d at 1068-69 (holding that a loan made to a friend for wholly personal reasons was not a "debt" as defined by the FDCPA because the borrower invested the borrowed funds as venture capital in a software company).
cited Cited as authority (rule) Micks v. Gurstel Law Firm, P.C.
D. Minnesota · 2019 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992).
discussed Cited as authority (rule) Aspen Skiing Co. v. Cherrett (In Re Cherrett) (2×)
9th Cir. · 2017 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir. 1992).
cited Cited as authority (rule) Lowe v. Maxwell & Morgan PC
D. Ariz. · 2017 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992) (internal quotation and citation omitted).
cited Cited as authority (rule) Heejoon Chung v. U.S. Bank, N.A.
D. Haw. · 2017 · confidence medium
System, Inc., 972 F.2d 1067, 1068 (9th Cir. 1992)).
cited Cited as authority (rule) Martin v. Allied Interstate, LLC
S.D. Fla. · 2016 · confidence medium
Bloom v. I.C, Sys., Inc,, 972 F.2d 1067, 1068-69 (9th Cir.1992); see also Hepsen v. J.C.
discussed Cited as authority (rule) In re: Allana Baroni
9th Cir. BAP · 2015 · confidence medium
Sys., Inc., 14 972 F.2d 1067, 1068 (9th Cir. 1992). 15 Here, the summary judgment record establishes that the 16 Carmel loan was used to refinance the Carmel property, and in her 17 bankruptcy filings, Allana repeatedly admitted that the Carmel 18 property was not used as the Baronis’ residence, but 19 rather was used as a rental property to generate income.12 Under 20 these circumstances, we hold that the bankruptcy court correctly 21 determined that the Carmel refinancing loan was not a debt 22 covered by the FDCPA.
discussed Cited as authority (rule) In re: Allana Baroni
9th Cir. BAP · 2015 · confidence medium
Sys., Inc., 14 972 F.2d 1067, 1068 (9th Cir. 1992). 15 Here, the summary judgment record establishes that the 16 Carmel loan was used to refinance the Carmel property, and in her 17 bankruptcy filings, Allana repeatedly admitted that the Carmel 18 property was not used as the Baronis’ residence, but 19 rather was used as a rental property to generate income.12 Under 20 these circumstances, we hold that the bankruptcy court correctly 21 determined that the Carmel refinancing loan was not a debt 22 covered by the FDCPA.
discussed Cited as authority (rule) James R. and Jamila J. Fleet v. Webber Springs Owners Assoc.
W. Va. · 2015 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir.1992) (holding that the FDCPA applies only to “consumer debts” incurred “primarily for personal, family, or household purposes”); Nance v. Petty, Livingston, Dawson, & Devening, 881 F. Supp. 223, 225 (W.D.
discussed Cited as authority (rule) James R. and Jamila J. Fleet v. Webber Springs Owners Assoc.
W. Va. · 2015 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir.1992) (holding that the FDCPA applies only to “consumer debts” incurred “primarily for personal, family, or household purposes”); Nance v. Petty, Livingston, Dawson, & Devening, 881 F.Supp. 223, 225 (W.D.Va.1994) (refusing to find homeowners association fee a “debt” under FDCPA inasmuch it was a “nonconsumer” debt).
discussed Cited as authority (rule) Fermin Aniel v. Aurora Loan Services LLC (2×)
9th Cir. · 2013 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir.1992).
discussed Cited as authority (rule) McDermott v. Marcus, Errico, Emmer & Brooks, P.C.
D. Mass. · 2012 · confidence medium
System, Inc., 972 F.2d 1067, 1068 (9th Cir.1992) (FDCPA “applies to consumer debts and not business loans” and then quoting section 1692a(5)); Fleet National Bank v. Baker, 263 F.Supp.2d 150, 153 (D.Mass.2003) (whether debt constitutes consumer debt “covered by the FDCPA, depends on the character of the lending transaction with particular attention to the purpose for which the credit was extended”); Business Lenders, LLC v. Gdzak, 2005 WL 1353378 , at *4 (D.Me.
cited Cited as authority (rule) Robert Smith v. EVB
4th Cir. · 2011 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir.1992).
cited Cited as authority (rule) Goldsmith v. HSW FINANCIAL RECOVERY, INC.
D.N.H. · 2010 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir.1992).
cited Cited as authority (rule) Town and Country Leasing v. Dubois
Me. Super. Ct · 2010 · confidence medium
Sys., Inc., 972 F.2d 1067, 1068 (9th Cir. 1992); Perry v. Stewart Title Co., 756 F.2d 1197, 1208 (5th Cir. 1985).
cited Cited as authority (rule) Gorman v. Wolpoff & Abramson, LLP
9th Cir. · 2009 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir.1992) (concluding that a furnisher does not act with malice when it takes “reasonable steps to verify the information” in its credit report).
discussed Cited as authority (rule) Gorman v. Wolpoff & Abramson
9th Cir. · 2009 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir. 1992) 27 We do not decide whether the debt related to the Four Peaks charge is valid, as the question is not before us. 28 Gorman’s essential claim is that in rejecting the goods and making them available to Four Peaks for pickup, he has done all that is required under California law.
cited Cited as authority (rule) Calloway v. Green Tree Servicing, LLC
D. Del. · 2009 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir.1992); Thornton v. *676 Equifax, Inc., 619 F.2d 700, 703 (8th Cir. 1980).
cited Cited as authority (rule) Gorman v. Wolpoff & Abramson, LLP
9th Cir. · 2009 · confidence medium
Sys., Inc., 972 F.2d 1067, 1069 (9th Cir.1992) (concluding that a furnisher does not act with malice when it takes “reasonable steps to verify the information” in its credit report).
discussed Cited as authority (rule) Simmonds and Narita LLP v. Schreiber (2×) also: Cited "see"
N.D. Cal. · 2008 · confidence medium
System, 972 F.2d 1067, 1068 (9th Cir.1992).
Retrieving the full opinion text from the archive…
Michael BLOOM, Plaintiff-Appellant,
v.
I.C. SYSTEM, INC., a Minnesota Corporation, Defendant-Appellee
18-50204.
Court of Appeals for the Ninth Circuit.
Aug 10, 1992.
972 F.2d 1067
Richard L. Grant, Portland, Or., for plaintiff-appellant., Andrew R. Gardner, Stoel, Rives, Boley, Jones & Grey, Portland, Or., for defendant-appellee.
Goodwin, Tang, Thompson.
Cited by 107 opinions  |  Published
GOODWIN, Circuit Judge:

This case involves a loan between two friends that was erroneously reported to a debt collection agency. In 1985, plaintiff[*1068] Michael Bloom, an attorney, borrowed $5,000 from his friend, Steven Parker. Bloom used the proceeds from the loan as a venture capital investment in a software company. Parker did not necessarily know or care what the money was being used for.

Parker is an insurance agent and president of Parkwest Insurance Services, Inc., (“Parkwest”). In 1988, Parkwest entered into a contract with defendant I.C. System (“I.C.”) for debt collection services. Unknown to Parker, a Parkwest employee submitted a debt for collection listing Bloom as the debtor. I.C. commenced collection efforts.

Bloom notified Parker of the mistake and Parker made efforts by phone and letter to explain that Bloom’s reported debt was an error. I.C. responded by requesting further written documentation to verify the fact that no debt was owed. Thereafter, I.C. listed the debt as contested.

In May 1989, Bloom filed suit against I.C. alleging unlawful debt collection practices in violation of the Fair Debt Collection Practices Act (“FDCPA”), see 15 U.S.C. §§ 1692e, 1692f, as well as an alternative state law claim for libel. The district court granted the defendant’s motion for summary judgment on both claims. See Bloom v. I.C. System, Inc., 753 F.Supp. 314 (D.Or. 1990). We affirm.

I.

The FDCPA protects consumers from unlawful debt collection practices. Consequently, the Act applies to consumer debts and not business loans. The term “debt” is defined as:

[A]ny obligation or alleged obligation of a consumer to pay money arising out of a transaction in which the money, property, insurance, or services which are the subject of the transaction are primarily for personal, family, or household purposes ...

15 U.S.C. § 1692a(5) (emphasis added).

Bloom correctly argues that given the small number of cases interpreting the term “debt” under the FDCPA, courts in other jurisdictions have looked for guidance to cases interpreting analogous provisions of the Consumer Credit Protection Act, 15 U.S.C. §§ 1601 to 1693r, such as the Truth in Lending Act (“TILA”). [1] See Zimmerman v. HBO Affiliate Group, 834 F.2d 1163, 1168 (3d Cir.1987). When classifying a loan, courts typically “examine the transaction as a whole,” paying particular attention to “the purpose for which the credit was extended in order to determine whether [the] transaction was primarily consumer or commercial in nature.” Tower v. Moss, 625 F.2d 1161, 1166 (5th Cir.1980).

The interpretation of the term “debt” under the FDCPA is apparently a matter of first impression for this court. Bloom urges us to characterize the loan as personal rather than commercial because the loan was informal in nature, with none of the trappings of a commercial loan, and because Parker’s motivation in lending the money was personal rather than business in nature. We are not persuaded. The fact that a loan is informal or that the lender may have loaned the money for personal reasons does not make it a personal loan under the FDCPA. The Act characterizes debts in terms of end uses, covering debts incurred “primarily for personal, family or household purposes.” Neither the lender’s motives nor the fashion in which the loan is memorialized are dispositive of this inquiry.

How Bloom actually spent the money is not disputed. Bloom invested the proceeds of the loan as venture capital in a software company with which he was closely associated. Bloom candidly admitted in his deposition that this was the intended purpose of the loan.

[*1069] Q. [By Mr. Gardner] And what was the purpose of the loan or of borrowing the money? What was your purpose in borrowing $5,000?
A. [By Mr. Bloom] I used the money for venture capital in an investment I was involved in, in and about that time.

The only issue is whether this intended use can be characterized as “primarily for personal, family or household purposes.” We hold that it cannot. Bloom borrowed the money to invest in a . software company. This was a business loan.

Bloom cites Thorns v. Sundance Properties, 726 F.2d 1417 (9th Cir.1984), for the proposition that, under the TILA, the mere fact that a loan is used for investment purposes does not necessarily render it a commercial loan. Thoms held that the factors employed by the Federal Eeserve Board under Eegulation Z, see 12 C.F.E. § 226 Supp. 1, § 226.3(a)(2), are relevant in determining whether a transaction is commercial or personal for the purposes of the Truth in Lending Act. See 726 F.2d at 1419. The Thoms court expressed no opinion as to the factual issues involved in the case and stated that “[w]hether an investment loan is for a personal or a business purpose requires a case by case analysis.” Id.

Even if we were to apply the factors identified in Thoms, it would not alter our conclusion. Bloom was president of the company he invested in and he represented the venture in his capacity as an attorney. Consequently, Bloom, the borrower, personally managed important aspects of the investment. Finally, the stated purpose of the loan was “for venture capital in. an investment.” The Thorns factors simply reinforce the contention that this was a commercial loan. [2]

II.

The Fair Credit Eeporting Act (“FCEA”) requires credit reporting, agencies to disclose extensive credit information to consumers. See 15 U.S.C. § 1681g. To limit the potential scope of liability for these agencies, Congress preempted state common law defamation claims.

Except as provided in §§ 1681n and 1681o of this title, no consumer may bring any action or proceeding in the nature of defamation ... with respect to the reporting of information against any consumer reporting agency, any user of information, or any person who furnishes information to a consumer reporting agency, based on information disclosed pursuant to 1681g ..., except as to false information furnished with malice or willful intent to injure such consumer.

15 U.S.C. § 1681h(e) (emphasis added).

Bloom argues that I.C. acted with malice because it refused to delete information regarding .the debt. A collection agency does not have a duty to delete all references to a debt whenever such debt is contested. I.C. reported the debt as disputed when it learned of the controversy. Moreover, the record demonstrates that I.C. took reasonable steps to verify the information in the report.

The following facts are not in dispute. In late 1988, under a contract with Parkwest which provided that “[a]ll accounts submitted to I.C. ... will be deemed assigned and set over to I.C. for collection, and will be validly due and owing by the debtor,” I.C. received a debt naming Bloom as the debtor. Upon Bloom’s prompting, Parker made phone calls and wrote letters stating that no debt existed. In March 1989, I.C. requested further written verification that no debt was owed. Thereafter, I.C. informed credit reporting agencies that the debt was disputed. In May 1989, Bloom filed suit.

Bloom argues that it was “false” to report the debt as disputed because both Bloom and Parker represented that no debt existed.. The representations of the parties do not explain, from I.C.’s perspective, how or why such a loan was submitted for collection in the first place. The debt had[*1070] been properly submitted under a valid contract. Under the circumstances, I.C.’s decision to list the debt as disputed and to seek written verification that no debt was in fact owed was not unreasonable.. Such conduct does not constitute malice or the willful intent to injure.

The district court’s grant of summary judgment is AFFIRMED.

1

. The TILA defines a consumer loan as:

"[A transaction] in which the party to whom credit is offered or extended is a natural person, and the money, property, or services which are the subject of the transaction are primarily for personal, family, or household purposes."

15 U.S.C. § 1602(h).

2

. Given that nothing turns on the issue, we leave open the question of whether the standards governing what constitutes a consumer debt under the FDCPA may ever differ from those determining what constitutes a consumer loan under the TILA.