Following a Third Circuit ruling last year finding a debtor's account number on the outside of an envelope violates the Fair Debt Collection Practices Act, a Pennsylvania federal judge has ruled embedding that number in a bar code is equally problematic given the advent of smartphone bar-code readers.

The judge determined the use of the bar code increases the risk that the receiver could be a victim of identity theft.

U.S. District Judge William J. Nealon of the Middle District of Pennsylvania denied ARS National Services Inc.'s motion for judgment on the pleadings, holding in his opinion Wednesday that the debt collector violated Section 1692f(8) of the FDCPA by including information other than its address on an envelope.