doctrine to an FDCPA claim. At least one court of appeals has stated in dicta that a defendant’s collection activities might amount to a continuing violation of the FDCPA. See Solomon v. HSBC Mortg. Corp., 395 Fed.Appx. 494, 497 n. 3 (10th Cir.2010). But that case included FDCPA claims related to an allegedly baseless foreclosure action, and the court concluded that the deceptive acts alleged in the complaint, including the foreclosure action, were discrete acts rather than continuing violations. Id. at 497. No court of appeals has held that debt-collection litigation (or a misleading statement made in connection with that litigation) is a continuing violation of the FDCPA. See Schaffhauser v. Citibank (S.D.) N.A., 340 Fed.Appx. 128, 131 (3d Cir.2009) (per cu- riam) (<HOLDING>); Naas v. Stolman, 130 F.3d 892, 893 (9th
holding that discriminatory pay reduction under fair labor standards act does not constitute continuing violation holding that failure to appear for sentencing is a continuing offense because a convicted criminal has a continuing obligation to face sentencing and presents an ongoing threat to the integrity and authority of the court so long as he has not appeared holding that title vii does not include a continuing violation doctrine holding that ongoing debtcollection litigation does not constitute a continuing violation of the fdcpa holding that because a  1326 violation constitutes a continuing offense venue may lie in any district in which the continuing conduct occurred