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Jeremy Cobb submitted an apartment rental application to Common Properties Management Coop- erative (Common) over the phone. Cobb authorized Common to debit his checking account

Jeremy Cobb submitted an apartment rental application to Common Properties Management Coop- erative (Common) over the phone. Cobb authorized Common to debit his checking account for the $37.95 application fee. However, the debit was returned by Cobb's bank as unpaid, and Cobb was assessed a Non-sufficient Funds (NsF) fee of $35.00 by Cobb's bank, along with a $25.00 "returned fee" by PayLease, LLC (PayLease), Common's financial institution. Cobb sued under the eFta, alleg- ing that the $25.00 "returned fee" had not been authorized. was the $25.00 returned fee to Pay- Lease covered by the EFTA?

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