administrative remedies as are available. (2) the exhaustion of administrative remedies under paragraph (1) may not be required unless the Attorney General has certified or the court has determined that such administrative remedies are in substantial compliance with the minimum acceptable standards promulgated under subsection (b) of this section or are otherwise fair or effective. 42 U.S.C. § 1997e(a) (1994) (amended 1996). 11 . Webster’s International Dictionary 180 (3d ed.1993). 12 . Oxford English Dictionary Vol. I, 812 (2d ed.1989). 13 . Id. 14 . Roget’s International Thesaurus 1171 (4th ed.1977). 15 . Random House Dictionary Of The English Language 1213 (Unabridged ed.1981). 16 . Oxford English Dictionary Vol. XIII, 584 (2d ed.1989). 17 . See, e.g. Lacey, 990 F.Supp. at 1205 (<HOLDING>); Whitley, 158 F.3d at 886-87 (holding that a
holding that the statement failure to pay will leave our client with no choice but to consider legal action did not violate  1692e5 by threatening legal action because at most the language  threatened that the creditor will have to consider legal action and therefore no action of any kind is threatened by defendant collection agency holding that ignorance of the law or legal procedure is no excuse for filing a frivolous action holding that judicial review of final agency action under the administrative procedure act  provides the proper procedure to challenge the sufficiency of an eis holding that when the administrative procedure is not empowered to achieve the end sought in the legal action the procedure is unavailable because it cannot accomplish the purpose of the legal action holding that when an agency fails to follow the proper procedure under the illinois administrative procedure act for the adoption of rules the rule is invalid