Echlin received treatment at PeaceHealth medical center but failed to pay for those services despite several requests. PeaceHealth contracted with CCI, a purported collection agency, to send collection letters to Echlin. After two letters were sent, the account was returned to PeaceHealth and CCI did not participate further. CCI controlled the content of the collection letters, the letters were on CCI letterhead and listed CCI’s contact information, including its website. Any responses received from debtors were handled by CCI, but CCI could not negotiate on behalf of PeaceHealth, and any payments received by CCI were simply sent on to PeaceHealth. A debt collection strategy called “flat rating” is forbidden under the Fair Debt Collection Practices Act. Flat rating involves a situation where the creditor hires a third party to send delinquency letters to a debtor. The third party portrays itself as a debt collector, but the third party has no further meaningful role in the collection process which, in fact, is being controlled by the creditor. Were PeaceHealth and CCI engaging in an unlawful flat-rating scheme?