under Section 1692g(a)(5), the request had to be in writing. As Welker argues, the Ninth Circuit in Camacho v. Bridgeport Fin. Inc. observed that the FDCPA “assigns lesser rights to debtors who orally dispute a debt and greater rights to debtors who dispute it in writing.” 430 F.3d 1078, 1082 (9th Cir.2005). “The plain meaning of § 1692g is that debtors can trigger the rights under subsection (a)(3) by either an oral or written ‘dispute,’ while debtors can trigger the rights under subsections (a)(4) and (a)(5) only through written dispute.” Id. (emphasis added). The Ninth Circuit in Camacho, however, was only faced with the question of whether adding the “in writing” requirement to where it was not statutorily required violated the FDCPA. Id. The court concluded that it did. Id. (<HOLDING>). Nonetheless, by extension, Camacho’s
holding that collection notice was potentially misleading because least sophisticated consumer could conclude that total amount stated as due was due at any time when in fact it was increasing holding that the defendants collection notice violated  1692g insofar as it stated that disputes under subsection a3 had to be in writing holding that a debt collectors violation of the overshadowing rule was a circumvention of  1692g holding therefore that although defendants failure to provide plaintiff with sufficient notice of termination and a pretermination hearing violated his right to procedural due process defendants motion for summary judgment should be granted insofar as it seeks to bar plaintiff from recovering more than a nominal amount holding that if congress had intended to obligate every subsequent debt collector beyond the first to provide validation notice it would have explicitly called for it in 15 usc section 1692g