The Sixth Circuit recently weighed in on whether there is a “benign language” exception to Section 1692f(8) of the Fair Debt Collection Practices Act (the “FDCPA”). In Donovan v. FirstCredit, Inc., No. 20-3485, 2020 U.S. App. LEXIS 39798 (6th Cir. Dec. 18, 2020), the Court joined the Third and Seventh Circuits in holding that Section 1692f(8)’s plain text unambiguously prohibits markings on envelopes other than those necessary for sending communications through the mail.