(United States Court of Appeals for the District of Columbia Circuit 2017) – Confirming lower court ruling that debt collection activities of law firm is not a “trade practice” under the District of Columbia Consumer Practices and Procedures Act; remanding attorney fee award for District Court’s failure to conduct a de novo review of a Magistrate Judge’s Recommendation of $41,000.00 in attorney fees on FDCPA claim; concurring opinion observed that a grossly excessive fee petition for $221,000.00 in an FDCPA claim settled by offer of judgment was “steep overbilling (that) ought to come at a steep price”, suggesting that an award for $1001.00 in fees would not be an abuse of discretion.