1000 (8th Cir.2011) (alteration in original) (quoting Richmond v. Higgins, 435 F.3d 825, 828 (8th Cir.2006)). “A violation of the FDCPA is reviewed utilizing the unsophisticated-consumer standard which is ‘designed to protect consumers of below average sophistication or intelligence without having the standard tied to the very-last rung on the sophistication ladder.’ ” Strand v. Diversified Collection Serv., Inc., 380 F.3d 316, 317 (8th Cir.2004) (quoting Duffy v. Landberg, 215 F.3d 871, 874 (8th Cir.2000)). The FDCPA is a strict liability statute. See Picht v. John R. Hawks, Ltd., 236 F.3d 446, 451 (8th Cir.2001) (discussing the “strict liability imposed upon debt collectors by the FDCPA”); see also Clark v. Capital Credit & Collection Servs., Inc., 460 F.3d 1162, 1176 (9th Cir.2006) (<HOLDING>); Ross v. Vakulskas Law Firm, PC, No;
holding that the district court erred in finding violations that were not alleged specifically in the plaintiffs notice letter and no penalties could be imposed for those violations holding that violations of fdcpa need not be knowing or intentional holding that the jury need only decide the ultimate issue of intentional discrimination and usually need not make findings on the prima facie case or whether the defendants explanation is pretextual holding that individual defendants may not be held liable for violations under title vii holding that a  1983 cause of action lies where police officers as opposed to prosecutors engaged in an intentional coverup thereby depriving a person of the right to recover for constitutional violations