quotation marks and emphasis omitted). The offending communication in that case happened to be sent to a debtor’s counsel, id. at 293, 115 S.Ct. 1489, but the question on review was the entirely different matter of whether a law firm engaged in collecting a debt is a debt collector for purposes of the Act. The identity of the recipient was mentioned in passing; neither the Court nor the parties addressed the issue now before us. We are not required to follow what amounts to, at most, an implicit assumption, because “[s]uch unstated assumptions on non-litigated issues are not precedential holdings binding future decisions.” Sakamoto v. Duty Free Shoppers, Ltd., 764 F.2d 1285, 1288 (9th Cir.1985); see also Brecht v. Abrahamson, 507 U.S. 619, 630-31, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993) (<HOLDING>); Webster v. Fall, 266 U.S. 507, 511, 45 S.Ct.
recognizing that the doctrine of stare decisis embodies the obligation to follow precedent holding that the doctrine of stare decisis is most frequently applied in cases affecting real property holding that the doctrine of stare decisis applies to the issue of reliability of new scientific techniques the intoxilyzer in that case holding that decision by panel of this court is established precedent under rules of stare decisis holding that stare decisis is not applicable unless the issue was squarely addressed in a prior decision