Civil Procedure 502.4(c), which authorizes the filing of a lawsuit in the county of the plaintiffs residence when the defendant’s residence is unknown, “should not be pre-empted by the FDCPA.” . Onwuteaka’s argument is not only merit-less, but frivolous and sanctionable. On-wuteaka’s sole authorities for the premise that' mistakes of law qualify for the bona fide error defense are Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA, 538 F.3d 469 (6th Cir.2008), and Taylor v. Luper, Sheriff & Niedenthal Co., L.P.A., 74 F.Supp.2d 761 (S.D.Ohio 1999). The Supreme Court granted certiorari in Jer-man and ultimately reversed the Sixth Circuit on precisely this point. See Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA 559 U.S. 573, 130 S.Ct. 1605, 1624-25, 176 L.Ed.2d 519 (2010) (<HOLDING>). Despite including outdated subsequent history
holding that the name under which a debt collector is licensed to do business is the debt collectors true name for purposes of the fdcpa holding that a debt collectors filing of a lawsuit on a debt that appears to be timebarred  is an unfair and unconscionable means of collecting the debt holding that the bona fide error defense in  1692kc does not apply to a violation of the fdcpa resulting from a debt collectors incorrect interpretation of the requirements of that statute and reversing the contrary judgment of the court of appeals holding that fdcpa was intended to protect consumers from communications initiated by debt collectors not consumers holding that it was error for the court to rule that the statement of mortgage debt was incorrect prior to submission of the auditors statement of account