Gary L. Veach v. Charles R. Sheeks, 316 F.3d 690 (7th Cir. 2003). · Go Syfert
Gary L. Veach v. Charles R. Sheeks, 316 F.3d 690 (7th Cir. 2003). Cases Citing This Book View Copy Cite
“y stating the amount of the debt as 1,050, sheeks took it upon himself to hold veach liable for legal penalties that had not yet been awarded, penalties that for fdcpa purposes should have been separated out from the amount of the debt.”
132 citation events (132 in the last 25 years) across 23 distinct courts.
Negative lean: 6th  ·  Positive lean: 2nd, 10th, 7th
Strongest positive: Barnes, Christipher v. Advanced Call Center (ca7, 2007-07-12) · Strongest negative: Gionis v. Javitch, Block & Rathbone, LLP (ca6, 2007-06-06)
Treatment trajectory · 2003 → 2026 · click a year to view as-of
2003 2014 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
examined Cited "but see" Gionis v. Javitch, Block & Rathbone, LLP (6×) also: Cited "see", Cited as authority (verbatim quote)
6th Cir. · 2007 · signal: but see · 1 verbatim quote · confidence high
when there are two different accounts of what a debtor actually owes the creditor, that one version is the correct description does not save the other . . . under the unsophisticated debtor standard . . . .
examined Cited as authority (verbatim quote) Barnes, Christipher v. Advanced Call Center
7th Cir. · 2007 · signal: see · quote attribution · 1 verbatim quote · confidence high
y stating the amount of the debt as 1,050, sheeks took it upon himself to hold veach liable for legal penalties that had not yet been awarded, penalties that for fdcpa purposes should have been separated out from the amount of the debt.
cited Cited as authority (rule) Kenneth Pucillo v. National Credit Systems, Inco
7th Cir. · 2023 · confidence medium
Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003).
cited Cited as authority (rule) Kenneth Pucillo v. National Credit Systems, Inco
7th Cir. · 2023 · confidence medium
Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003).
cited Cited as authority (rule) White v. Resurgent Capital Services, LP
S.D. Ill. · 2023 · confidence medium
Lox v. CDA, Ltd., 689 F.3d 818, 822 (7th Cir. 2012) (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003)).
discussed Cited as authority (rule) Wilson v. AFNI, Inc.
N.D. Ill. · 2022 · confidence medium
The unsophisticated consumer contemplated by this standard may be “uninformed, naive, [and] trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003), but is not a dimwit, has “rudimentary knowledge about the financial world,” and is “capable of making basic logical deductions and inferences,” Wahl, 556 F.3d at 645 .
cited Cited as authority (rule) Chisom v. AFNI, Inc.
N.D. Ill. · 2021 · confidence medium
Lox, 689 F.3d at 822 (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003)).
discussed Cited as authority (rule) Banks v. Kottemann Law Firm
M.D. La. · 2021 · confidence medium
Here, “no judgment has been rendered . . . [n]or has a collection lawsuit ever been filed against Plaintiff.” (Doc. 10 at 17.) In Veach v. Sheeks, the Seventh Circuit explained that the debtor “cannot be held liable for treble damages, court costs, or attorney's fees [which were authorized by statute] until there has been a judgment by a court” and therefore, “they cannot be part of the ‘remaining principal balance’ of a claimed debt.” 316 F.3d 690, 693 (7th Cir. 2003) (emphasis in original).
discussed Cited as authority (rule) Schmeling v. United Collection Bureau Inc
E.D. Wis. · 2020 · confidence medium
Under this standard, the letter “must be clear and comprehensible to an individual who is ‘uniformed, naïve, [and] trusting,’ but not without a rudimentary knowledge about the financial world or incapable of making basic deductions and inferences.” Id. (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003)).
discussed Cited as authority (rule) Nagan v. Optio Solutions LLC
E.D. Wis. · 2020 · confidence medium
Though the unsophisticated consumer may be “uniformed, naïve, [and] trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003), “she has rudimentary knowledge about the financial world and is capable of making basic logical deductions and inferences.” Wahl v. Midland Credit Mgmt., Inc., 556 F.3d 643, 645 (7th Cir. 2009) (internal quotation marks and citations omitted); see also Pettit, 211 F.3d at 1060 (noting that the unsophisticated consumer has at least a “rudimentary knowledge about the financial world, is wise enough to read collection notices with added care, possesses ‘r…
discussed Cited as authority (rule) Reitz v. Credit Systems of the Fox Valley, Inc.
E.D. Wis. · 2020 · confidence medium
Under this standard, the letter “must be clear and comprehensible to an individual who is ‘uninformed, naive, [and] trusting,’ but not without a rudimentary knowledge about the financial world or incapable of making basic deductions and inferences.” Id. (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003)).
discussed Cited as authority (rule) Morris v. Jefferson Capital Systems, LLC
N.D. Ill. · 2020 · confidence medium
But, as the Yan Lin court noted, adding a sentence to the affidavit that Defendants were seeking court costs “could have been misleading, by conflating information about the claimed debt with court costs, which could have given rise to an FDCPA violation.” 2020 WL 1939186 , at *5 (citing Veach v. Sheeks, 316 F.3d 690, 691-92 (7th Cir. 2003) (holding that court costs and attorney’s fees are not a component of a “debt” under the FDCPA and since plaintiff could not be held liable for treble damages, court costs, or attorney’s fees until there had been a judgment by a court, those pena…
discussed Cited as authority (rule) Owens, Stephanie v. United Credit Service Inc.
W.D. Wis. · 2020 · confidence medium
Although the unsophisticated consumer is “uninformed, naïve, and trusting,” courts emphasize that she is not a “dimwit.” Wahl v. Midland Credit Mgmt., Inc., 556 F.3d 643, 645 (7th Cir. 2009) (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003)).
discussed Cited as authority (rule) Hernandez v. BC Services, Inc.
S.D. Ill. · 2020 · confidence medium
The unsophisticated consumer is not a “dimwit” but “may be ‘uninformed, naive, [and] trusting[]’” with “‘rudimentary knowledge about the financial world.’” Wahl, 556 F.3d at 645 (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003) and Pettit v. Retrieval Masters Creditors Bureau, Inc., 211 F.3d 1057, 1060 (7th Cir. 2000)).
discussed Cited as authority (rule) Degroot v. Client Services, Inc.
E.D. Wis. · 2020 · confidence medium
Though the unsophisticated consumer may be “uniformed, naive, [and] trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003), “she has rudimentary knowledge about the financial world and is capable of making basic logical deductions and inferences.” Wahl v. Midland Credit Mgmt., Inc., 556 F.3d 643, 645 (7th Cir. 2009) 7 (internal quotation marks and citations omitted); see also Pettit, 211 F.3d at 1060 (noting that the unsophisticated consumer has at least a “rudimentary knowledge about the financial world, is wise enough to read collection notices with added care, possesses ‘…
discussed Cited as authority (rule) Schmitt v. Messerli & Kramer, P.A.
D. Neb. · 2019 · confidence medium
An unsophisticated consumer has “‘rudimentary knowledge about the financial world’ and is ‘capable of making basic logical deductions and inferences.’” Wahl v. Midland Credit Mgmt., Inc., 556 F.3d 643, 645 (7th Cir. 2009) (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003); Pettit v. Retrieval Masters Creditors Bureau, Inc., 211 F.3d 1057, 1060 (7th Cir. 2000)).
discussed Cited as authority (rule) Hernandez v. BC Services, Inc.
S.D. Ill. · 2019 · confidence medium
The unsophisticated consumer is not a “dimwit” but “may be ‘uninformed, naïve, [and] trusting” with “rudimentary knowledge about the financial world.” , 556 F.3d at 645 (quoting , 316 F.3d 690, 693 (7th Cir. 2003) and , 211 F.3d 1057, 1060 (7th Cir. 2000)).
discussed Cited as authority (rule) Patricia Koehn v. Delta Outsource Group, Incorpo
7th Cir. · 2019 · confidence medium
An unsophisticated consumer is “uninformed, naïve, or trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003), but nonetheless possesses “reasonable in- telligence,” basic knowledge about the financial world, and “is wise enough to read collection notices with added care.” Gruber v. Creditors' Protection Service, Inc., 742 F.3d 271, 273 (7th Cir. 2014) (quotations omitted).
discussed Cited as authority (rule) Patricia Koehn v. Delta Outsource Group, Incorpo
7th Cir. · 2019 · confidence medium
An unsophisticated consumer is “uninformed, naïve, or trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003), but nonetheless possesses “reasonable in- telligence,” basic knowledge about the financial world, and “is wise enough to read collection notices with added care.” Gruber v. Creditors' Protection Service, Inc., 742 F.3d 271, 273 (7th Cir. 2014) (quotations omitted).
discussed Cited as authority (rule) Schmitt v. Messerli & Kramer, P.A.
D. Neb. · 2019 · confidence medium
An unsophisticated consumer “may be ‘uninformed, naive, [and] trusting,’ but she has ‘rudimentary knowledge about the financial world’ and is ‘capable of making basic logical deductions and inferences.’” Wahl v. Midland Credit Mgmt., Inc., 556 F.3d 643, 645 (7th Cir. 2009) (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003); Pettit v. Retrieval Masters Creditors Bureau, Inc., 211 F.3d 1057, 1060 (7th Cir. 2000)).
cited Cited as authority (rule) HESS v. MERCHANTS & MEDICAL CREDIT CORPORATION, INC.
D.N.J. · 2019 · confidence medium
Servs., 362 F.3d 944, 949 (7th Cir. 2004) (citing Veach v. Sheeks, 316 F.3d 690, 692-93 (7th Cir. 2003)).
discussed Cited as authority (rule) Nieto v. MRS Associates
N.D. Ill. · 2018 · confidence medium
That is, the letter “must be clear and comprehensible to an individual who is ‘uninformed, naïve, [and] trusting,’ but not without a rudimentary knowledge about the financial world or incapable of making basic deductions and inferences.” Id. (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003)).
discussed Cited as authority (rule) Nieto v. MRS Associates
N.D. Ill. · 2018 · confidence medium
That is, the letter “must be clear and comprehensible to an individual who is ‘uninformed, naïve, [and] trusting,’ but not without a rudimentary knowledge about the financial world or incapable of making basic deductions and inferences.” Id. (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003); Wahl v. Midland Credit Mgmt., Inc., 556 F.3d 643, 645 (7th Cir. 2009)).
cited Cited as authority (rule) Speights-Carnegie v. The Blackstone Condominium Association
N.D. Ill. · 2018 · confidence medium
The unsophisticated consumer may be “uninformed, naïve, [and] trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003), but she is not a dimwit.
discussed Cited as authority (rule) Derosa v. Computer Credit, Inc. (2×)
E.D.N.Y · 2018 · confidence medium
Id. at 692, 694 .
discussed Cited as authority (rule) Irvine v. I.C. System, Inc.
D. Colo. · 2016 · confidence medium
The least sophisticated consumer is not a “dimwit,” but rather “uninformed, naive, and trusting.” Wahl v. Midland Credit Mgmt., Inc., 556 F.3d 643, 645-46 (7th Cir.2009) (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003)) (internal quotation marks omitted).
discussed Cited as authority (rule) Kalebaugh v. Cohen, McNeile & Pappas, P.C.
D. Kan. · 2015 · confidence medium
The standard is also referred to, in some circuits, as the “unsophisticated consumer test.” See, e.g., Veach v. Sheelcs, 316 F.3d 690, 692-93 (7th Cir.2003) (“When reviewing documents for compliance with the FDCPA, ... [the Seventh Circuit] use[s] the 'unsophisticated debtor’ standard.”); Duffy v. Landberg, 215 F.3d 871 , 874-75 (8th Cir.2000) (the unsophisticated consumer standard “protects the uninformed or naive consumer, yet also contains an objective element of reasonableness to protect debt collectors from liability for peculiar interpretations of collections letters.”); se…
examined Cited as authority (rule) Kalebaugh v. Berman & Rabin, P.A. (5×) also: Cited "see"
D. Kan. · 2014 · confidence medium
Thus, the Seventh Circuit concluded the “more precise benchmark is the understanding of ‘the unsophisticated debtor,’ a formulation which ‘assumes that the debtor is “uninformed, naive, or trusting,” [ but] that statements are not confusing or misleading unless a significant fraction of the population would be similarly misled.’ ” Id. at 949 (quoting Veach v. Sheeks, 316 F.3d 690, 692-93 (7th Cir.2003)).
discussed Cited as authority (rule) Phyllis Clark v. Main Street Acquisition Corp.
6th Cir. · 2014 · confidence medium
And in Veach v. Sheeks, 316 F.3d 690, 692 (7th Cir.2003), a collection agent sent a letter to an alleged guarantor of a debtor incorrectly stating the amount of the debt by holding the guarantor liable for legal penalties that had not yet been awarded.
discussed Cited as authority (rule) Winiecki v. Creditors Interchange Receivable Management, LLC
N.D. Ill. · 2014 · confidence medium
“The unsophisticated consumer may be uninformed, naive, and trusting, but is not a dimwit, has rudimentary knowledge about the financial world, and is capable of making basic logical deductions and inferences.” Lox v. CDA, Ltd., 689 F.3d 818, 822 (7th Cir.2012) (internal citations and quotation marks omitted) (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003); Wahl, 556 F.3d at 645 ).
discussed Cited as authority (rule) Simkus v. Cavalry Portfolio Services, LLC
N.D. Ill. · 2014 · confidence medium
Whether a violation occurs is viewed through an objective standard of the “unsophisticated consumer.” Fields v. Wilber Law Firm, P.C., 383 F.3d 562, 564 (7th Cir.2004); Veach v. Sheeks, 316 F.3d 690, 692 (7th Cir.2003).
discussed Cited as authority (rule) In re Martin
Bankr. W.D. Wis. · 2013 · confidence medium
“The unsophisticated consumer may be ‘uninformed, naive, [and] trusting,’ Id. (quoting Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003)), but is not a dimwit, has ‘rudimentary knowledge about the financial world,’ and is ‘capable of making basic logical deductions and inferences.’” Id. (quoting Pettit v. Retrieval Masters Creditors Bureau, Inc., 211 F.3d 1057,1060 (7th Cir.2000)). “[W]e treat the question of whether an unsophisticated consumer would find certain debt collection language misleading as a question of fact.” Id. (citing Walker v. Nat’l Recovery, Inc., 200 F.…
cited Cited as authority (rule) Trease v. Tri-State Adjustments, Inc.
E.D. Wis. · 2013 · confidence medium
In the court’s words, the debt collector demanded not “what the obligation [was]” hut “what the final, worst-case scenario could be.” Id. at 693 (emphasis omitted).
discussed Cited as authority (rule) Jeffrey Lox v. CDA Limited
7th Cir. · 2012 · confidence medium
The unsophisticated consumer may be “uninformed, naive, [and] trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003), but is not a dimwit, has “rudimentary knowledge about the financial world,” and is “capable of making basic logical deductions and inferences,” Wahl, 556 F.3d at 645 (quoting Pettit v. Retrieval Masters Creditors Bureau, Inc., 211 F.3d 1057, 1060 (7th Cir.2000)).
discussed Cited as authority (rule) Zemeckis v. Global Credit & Collection Corp.
7th Cir. · 2012 · confidence medium
The letter must be clear and comprehensible to an individual who is “uninformed, naive, [and] trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003), but not without a rudimentary knowledge about the financial world or incapable of making basic deductions and inferences, Wahl v. Midland Credit Mgmt., Inc., 556 F.3d 643, 645 (7th Cir.2009).
discussed Cited as authority (rule) Scheunemann v. J.C. Christensen & Associates, Inc.
E.D. Wis. · 2011 · confidence medium
They offer no other evidence showing that the original creditor statement was misleading or false or would be confusing to a “significant fraction of the population.” Veach v. Sheeks, 316 F.3d 690, 692-92 (7th Cir.2003).
discussed Cited as authority (rule) Daniels v. Davis Davis Attorneys, P.C.
pactcomplallegh · 2011 · confidence medium
E.g., Veach v. Sheeks, 316 F.3d 690, 691-92 (7th Cir. 2003) (notice of claim filed in small claims court misleading because it failed to specify amount of debt); Gearing v. Check Brokerage Corp., 233 F.3d 469 (7th Cir. 2000) (state court complaint stated incorrectly that debt collection agency had right of subrogation).
discussed Cited as authority (rule) Sullivan v. CREDIT CONTROL SERVICES, INC.
D. Mass. · 2010 · confidence medium
Under the “unsophisticated consumer” standard, “statements are not ... misleading unless a significant fraction of the population would be similarly misled.” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003) (describing the “unsophisticated consumer” as one who is “uninformed, naive, or trusting”); accord Duffy v. Landberg, 215 F.3d 871 , 874-75 (8th Cir.2000) (applying the unsophisticated consumer standard).
discussed Cited as authority (rule) Eichman v. MANN BRACKEN, LLC
W.D. Wis. · 2010 · confidence medium
E.g., Veach v. Sheeks, 316 F.3d 690, 691-92 (7th Cir.2003) (notice of claim filed in small claims court misleading because it failed to specify amount of debt); Gearing v. Check Brokerage Corp., 233 F.3d 469 (7th Cir.2000) (state court complaint stated incorrectly that debt collection agency had right of subrogation).
discussed Cited as authority (rule) Hutton v. LAW OFFICES OF COLLINS & LAMORE
S.D. Cal. · 2009 · confidence medium
It makes more sense to judge from “an unsophisticated debtor” standard, which “assumes that the debtor is ‘uninformed, naive, or trusting,’ and that statements are not confusing or misleading unless a significant fraction of the population would be similarly misled.” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003).
discussed Cited as authority (rule) Barbara Wahl v. Midland Credit Mgmt
7th Cir. · 2009 · confidence medium
She may be “uninformed, naive, [and] trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir. 2003), but she has “rudimentary knowledge about the financial world” and is “capable of making basic logical deductions and inferences,” Pettit v. Retrieval Masters Creditors Bureau, Inc., 211 F.3d 1057, 1060 (7th Cir. 2000).
discussed Cited as authority (rule) Wahl v. Midland Credit Management, Inc.
7th Cir. · 2009 · confidence medium
She may be “uninformed, naive, [and] trusting,” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003), but she has “rudimentary knowledge about the financial world” and is “capable of making basic logical deductions and inferences,” Pettit v. Retrieval Masters Creditors Bureau, Inc., 211 F.3d 1057, 1060 (7th Cir.2000).
discussed Cited as authority (rule) Evory, Tammy A. v. RJM Acquisitions Fun
7th Cir. · 2007 · confidence medium
As in previous cases in which we have created safe-harbor language for use in cases under the Fair Debt Collection Practices Act, see Veach v. Sheeks, 316 F.3d 690, 693-94 (7th Cir. 2003); Miller v. McCalla, Raymer, Padrick, Cobb, Nichols, & Clark, L.L.C., 214 F.3d 872, 876 (7th Cir. 2000); Bartlett v. Heibl, 128 F.3d 497 (7th Cir. 1997); cf. Diaz v. Prudential Ins.
discussed Cited as authority (rule) Evory v. RJM ACQUISITIONS FUNDING LLC
7th Cir. · 2007 · confidence medium
As in previous cases in which we have created safe-harbor language for use in cases under the Fair Debt Collection Practices Act, see Veach v. Sheeks, 316 F.3d 690, 693-94 (7th Cir.2003); Miller v. *776 McCalla, Raymer, Padrick, Cobb, Nichols, & Clark, L.L.C., 214 F.3d 872, 876 (7th Cir.2000); Bartlett v. Heibl, 128 F.3d 497 (7th Cir.1997); cf. Diaz v. Prudential Ins.
discussed Cited as authority (rule) Foster v. D.B.S. Collection Agency
S.D. Ohio · 2006 · confidence medium
See Shula v. Lawent, 359 F.3d 489, 491 (7th Cir. 2004); Veach v. Sheeks, 316 F.3d 690, 692 (7th Cir.2003) (holding that debt collector violated FDCPA when it held debtor liable for court costs that had not yet been awarded); Duffy v. Landberg, 215 F.3d 871 , 873-74 (8th Cir.2000).
discussed Cited as authority (rule) Hernandez v. AFNI, INC.
N.D. Ill. · 2006 · confidence medium
Based in large part on the implications of the legislative intent to protect debtors, courts apply the. “unsophisticated debtor standard,” - .which assumes that the debtor is “uninformed, naive, or trusting.” Id. at 1060 ; see also Fields v. Wilber Law Firm, P.C., 383 F.3d *780 562, 564 (7th Cir.2004); Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003).
discussed Cited as authority (rule) Gully v. Van Ru Credit Corp.
N.D. Ill. · 2005 · confidence medium
That standard “assumes that *768 the debtor is ‘uninformed, naive, or trusting,’ and that statements are not confusing or misleading unless a significant fraction of the population would be similarly misled.” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003) (quoting Pettit, 211 F.3d at 1060 ).
discussed Cited as authority (rule) Goins v. JBC & Associates, P.C.
D. Conn. · 2005 · confidence medium
This is impermissible, because “[t]he ‘amount of debt’ provision is designed to inform the debtor ... of what the obligation is, not what the final, worst-case scenario could be.” Veach v. Sheeks, 316 F.3d 690, 693 (7th Cir.2003) (emphasis in original).
discussed Cited as authority (rule) Fields, Jodi v. Wilber Law Firm (2×) also: Cited "see"
7th Cir. · 2004 · confidence medium
“This assumes that the debtor is uninformed, naive, or trusting[.]” Veach, 316 F.3d at 693 (internal quotations omitted).
discussed Cited as authority (rule) Fields v. Wilber Law Firm (2×) also: Cited "see"
7th Cir. · 2004 · confidence medium
"This assumes that the debtor is uninformed, naive, or trusting[.]" Veach, 316 F.3d at 693 (internal quotations omitted).
Retrieving the full opinion text from the archive…
Gary L. VEACH, Plaintiff-Appellant,
v.
Charles R. SHEEKS, Defendant-Appellee
02-1149.
Court of Appeals for the Seventh Circuit.
Jan 13, 2003.
316 F.3d 690
Clifford W. Shepard (argued), Indianapolis, IN, for Plaintiff-Appellant., G. Ronald Heath, Steven J. Moss (argued), Hoover Hull Baker & Heath, Indianapolis, IN, for Defendant-Appellee.
Coffey, Evans, Williams.
Cited by 83 opinions  |  Published
WILLIAMS, Circuit Judge.

Gary Veach appeals from the district court’s grant of judgment as a matter of law in favor of defendant Charles Sheeks. Veach alleged that Sheeks sent him bill collection letters that included court costs and attorney’s fees, which misstated the amount of the debt Veach owed in violation of both the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. § 1692 et seq., and Indiana’s deception statute, ind. Code 35^15-5-39(a)(2). We reverse the district court’s grant of summary judgment in favor of Sheeks as to Veach’s federal claim because court costs and attorney’s fees are not a component of a “debt” under the FDCPA, affirm the state law claim decided in Sheeks’s favor, and remand for further proceedings.

I. BACKGROUND

Veach’s girlfriend’s son was behind in his payments on his car, which was in danger of repossession. As a favor, Veach mailed to CreditNet, the finance company, a check for $350 to help reduce the overdue balance on the car. When the car was repossessed anyway, Veach stopped payment on the check. CreditNet then sent Veach a written notice indicating that the check had been dishonored and demanding that Veach make full payment on the check or face a lawsuit for appropriate legal remedies, including three times the amount of the check, interest, attorney’s fees and court costs. Since he was not a guarantor of the car loan, Veach did not feel he owed any money to CreditNet, and therefore was under no obligation to honor the check, so he ignored the notice and did not make any effort to reinstate payment on the check.

Faced with no response from Veach, CreditNet hired Sheeks to file suit against Veach on the dishonored check. Sheeks mailed Veach a notice of claim pursuant to the FDCPA, which also served as a summons and complaint for Indiana small claims court proceedings. In the small claims court proceeding, with CreditNet represented by Sheeks and Veach representing himself, the court found in Credit-Net’s favor, and issued judgment against Veach for $1,050, attorney’s fees of $350, and court costs. A few days later, Veach received a mailing from the court informing him of the judgment, which he discarded.

[*692] As a result of Veach’s non-payment of the small claims court judgment, his bank account was frozen, so he appealed the small claims court judgment to the Marion County Circuit Court. After the appeal was filed, CreditNet voluntarily moved to set aside the underlying small claims court judgment without prejudice. As a result of the appeal and the setting aside of the small claims court judgment against him, Veach never made any payments on the $350 check. Veach filed this FDCPA action against Sheeks in federal court, which proceeded to a jury trial. At the close of Veach’s case, Sheeks moved for judgment as a matter as a law, which the district court granted. [1] Veach now appeals.

II. ANALYSIS

We first note that what is not at issue here is whether or not Veach actually had an obligation to CreditNet for $350. What is at issue is whether Sheeks’ mailing to Veach complied with the FDCPA. We review the district court’s finding of judgment as a matter of law de novo, drawing all inferences in favor of Veach as the non-moving party. See Mathur v. Bd. of Trustees of S. Ill. Univ., 207 F.3d 938, 941 (7th Cir.2000).

A. Fair Debt Collection Practices Act Claim

Veach sued Sheeks under the remedial portion of the FDCPA, 15 U.S.C. § 1692k, which allows him to recover actual damages, a penalty of up to $1,000, and attorney’s fees for a violation of the FDCPA. Veach argues that Sheeks failed to comply with 15 U.S.C. § 1692g(a)(l), which requires a debt collector’s notice of claim to specify the “amount of the debt.” The notice of claim Sheeks sent Veach described the “amount of the claimed debt” as “Remaining principal balance $1,050.00; plus reasonable attorney fees as permitted by law, and costs if allowed by the court.” Because the amount of attorney’s fees and court costs due is not specified, Veach argues, there was not an “amount” stated for FDCPA purposes.

Sheeks claims that a “debt” is defined in the FDCPA as an “obligation or alleged obligation,” and that his general reference to fees and costs is permissible according to Indiana law and the FDCPA, since those were monies which he would be allowed to collect had his court action been successful. Also, Sheeks points out that to specify an amount for fees and costs before they are finalized by a court could cause Veach to pay more than the amount actually imposed as a result of court proceedings. In addition, Veach says the $1,050 figure is appropriate because that amount is an “alleged obligation,” incorporating the treble damages which Sheeks was allowed to pursue under Indiana Code 34-24-3-1.

We agree with Veach that Sheeks incorrectly stated the amount of the debt, but not because he specified indeterminate attorney’s fees and court costs. Rather, by stating the amount of the debt as $1,050, Sheeks took it upon himself to hold Veach liable for legal penalties that had not yet been awarded, penalties that for FDCPA purposes should have been separated out from the amount of the debt.

When reviewing documents for compliance with the FDCPA, such as the letters sent to Veach by Sheeks, we use the “unsophisticated debtor” standard.[*693] See Marshall-Mosby v. Corporate Receivables, Inc., 205 F.3d 323, 326 (7th Cir.2000); Bartlett v. Heibl, 128 F.3d 497, 500 (7th Cir.1997). This assumes that the debtor is “uninformed, naive, or trusting,” and that statements are not confusing or misleading unless a significant fraction of the population would be similarly misled. Pettit v. Retrieval Masters Creditor Bureau, Inc., 211 F.3d 1057, 1060 (7th Cir.2000).

In our earlier attempt to clarify the “amount of debt” provision of 15 U.S.C. § 1692g(a)(l), we described the following language as a safe harbor for debt collectors when the amount of the debt varies from day to day:

As of the date of this letter, you owe $_ [the exact amount due]. Because of interest, late charges, and other charges that may vary from day to day, the amount due on the day you pay may be greater. Hence, if you pay the amount shown above, an adjustment may be necessary after we receive your check, in which event we will inform you before depositing the check for collection. For further information, write the undersigned or call l-800-[phone number].

Miller v. McCalla, Raymer, Padrick, Cobb, Nichols, & Clark, L.L.C., 214 F.3d 872, 876 (7th Cir.2000). We suggested this language to prevent confusion by debtors for whom the “exact amount due” is a constantly shifting target due to accruing interest and accumulating unpaid charges. The reason for that variation, i.e., “interest, late charges, and other charges,” is explained in the sentence following the amount of the debt as of the letter’s date. What is missing from that language is any mention of court costs, attorney’s fees, or other penalties which may be imposed by statute. That is because the “amount of the debt” provision is designed to inform the debtor (who, remember, has a low level of sophistication) of what the obligation is, not what the final, worst-case scenario could be. The definition of a “debt” according to the FDCPA is of an “obligation or alleged obligation ... whether or not such obligation has been reduced to judgment.” 15 U.S.C. § 1692a(5). Since Veach cannot be held liable for treble damages, court costs, or attorney’s fees until there has been a judgment by a court, they cannot be part of the “remaining principal balance” of a claimed debt. Therefore, Sheeks’ notice misrepresented the actual debt CreditNet claimed that it was owed by Veach, a misrepresentation that violated 15 U.S.C. § 1692e.

Sheeks claims that the language he used was not misleading because the notice of claim and small claims court summons specified that “the Defendant is indebted to the Plaintiff in the sum of $1,050 as treble damages for a bad check in the sum of $350.00, plus reasonably [sic] attorney fees as permitted by law.” This argument is belied by the “unsophisticated debtor” standard which we use to review FDCPA documents. While the state court summons and notice of claim may have complied with the language of the FDCPA, the other notice of claim, which accompanied the state court summons and explicitly labeled “F.D.C.P.A.” across the top, provides the misleading information as described above. When there are two different accounts of what a debtor actually owes the creditor, that one version is the correct description does not save the other, since under the unsophisticated debtor standard, “a letter may confuse even though it is not internally contradictory.” Johnson v. Revenue Mgmt. Corp., 169 F.3d 1057, 1060 (7th Cir.1999).

We took the step once of providing “safe harbor” language in Miller so that creditors could craft a notice for claims that could pass muster under the FDCPA in[*694] volving fluctuating balances that varied from day to day. We do not think that we need to revisit our earlier language, since we have no dispute as to the outstanding balance. Sheeks knew that Veach allegedly owed CreditNet $350; by assuming the outcome of future events in drafting his notice, Sheeks ran afoul of the FDCPA. We leave for another day the question of whether it was enough to implicate the remedial provisions of the FDCPA.

B. Indiana Deception Claim

In addition to his FDCPA claim, Veach asserted that he was entitled to relief under Indiana Code 34-24-3-1, which allows someone to bring a civil action for treble damages, costs, and attorney’s fees if they suffer “a pecuniary loss” due to deception, defined in Indiana Code 35-43-5-3(a)(2) as “knowingly or intentionally makes a false or misleading written statement with intent to obtain property, employment, or an educational opportunity.” The district court granted judgment as a matter of law because, finding the notice of claim proper, it could not find any intent to deceive using the notice and an inflated debt amount. While we agree that judgment in favor of Sheeks was proper as a matter of law as to this point, our finding is predicated on the fact that Veach cannot show that he suffered any pecuniary loss as a result of the notice. “Pecuniary loss” is considered “a loss of money, or of something by which money, or something of money value may be acquired.” Amer icar Leasing, Inc. v. Maple, 406 N.E.2d 333, 335 (Ind.Ct.App.1980). Since Veach represented himself in his small claims court proceedings, was represented by a public interest law firm in his appeal of that proceeding, and did not pay any of the judgment levied against him, he suffered losses of time and effort, but not money. While his checking account was frozen at some point because of his nonpayment of the check, he has made no claim of financial loss as a result. Therefore, he cannot bring a claim under Indiana Code 34-24-3-1, and the district court’s grant of judgment as a matter of law regarding this claim was proper.

III. CONCLUSION

For the foregoing reasons, we Affirm the district court’s grant of judgment as a matter of law in favor of Sheeks as to Veach’s Indiana state law claim, ReveRSe the district court’s grant of judgment as a matter of law in favor of Sheeks as to his FDCPA claims, and Remand the case to the district court for a new trial in a manner consistent with this opinion.

1

. The district court did deny Sheeks' motion for judgment as a matter of law regarding Veach's 15 U.S.C. § 1692i claim, based on Sheeks’ filing his state court action in the incorrect county. This claim went to the jury, who found that Sheeks violated 15 U.S.C. § 1692i, but absolved him of liability pursuant to the bona fide error defense of 15 U.S.C. § 1692k(c). Veach does not appeal the jury's verdict.