Bates v. C & S Adjusters, Inc. 908 F.2d 865 (2d Cir. 1992) Bates received a collection notice from C&S, based on a debt he incurred while living in Pennsylvania. Instead of paying, he sued. Bates alleged a violation of the Fair Debt Collection Practices Act (FDCPA). Bates brought his case in a New York Federal Court. C&S filed a motion to dismiss for improper venue. C&S was located in the Western District of Pennsylvania. Bates presently lived in the Western District of New York. The New York Trial Court dismissed the claim for improper venue. Bates appealed. Bates argued that the case could be brought under 28 USC § 1391(b)(2), which allows action to be brought in a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred. The New York Appellate Court reversed the Trial Court's ruling, and remanded the case back to the Trial Court. The Appellate Court felt that the venue was proper under 28 USC § 1391(b)(2). 28 USC § 1391(b)(2) had been amended in 1990. Prior to that, it only allowed for a venue in the judicial district where the claim arose. Prior to 1966, the only venue available was the one in which the defendant had a domicile. The Court also noted that even prior to the 1990 amendment to 28 USC § 1391, several Courts had held that, under the FDCPA, a plaintiff could bring suit in their home district if a collection agency had mailed notice to their address in that district, of called them on the phone there.