the number of such debts exceeds the number of their consumer liabilities. Taking the contrary position, the UST argues that the Debtors have primarily consumer debts because the aggregate dollar amount of their consumer debt exceeds 50% of their total liabilities. Courts have interpreted the phrase “primarily consumer debts” in several different ways. The majority view is that a debtor’s liabilities are primarily consumer debts if the aggregate dollar amount of such debts exceeds 50% of the debtor’s total liabilities. See Hoffner, 2007 WL 4868310 at *2 (“The majority of courts that have considered the issue have found that ‘primarily’ means more than half of the total dollar amount owed.”). See also Stewart v. United States Tr. (In re Stewart), 175 F.3d 796, 808 (10th Cir.1999) (<HOLDING>); Kelly, 841 F.2d at 913 (same); Naut, 2008 WL
holding that the fdcpa applies only to consumer debts incurred primarily for personal family or household purposes holding that a debtor has primarily consumer debts if the aggregate amount of consumer debt is more than 50 of the total debt holding that debt collectors have no obligation to warn a consumer that her debt may increase over time holding that a credit transaction is not a consumer debt when it is incurred with a profit motive holding that a debt incurred for a personal family or household purpose is a consumer debt even though it is secured by the debtors real property