violation (or violations) was unintentional and the result of a "bona fide error" that occurred despite procedures designed to avoid the error at issue. Alternatively, if the consumer loses the lawsuit and the court determines that the consumer filed the case in bad faith and for the purposes of harassment, the court may then award attorney's fees to the debt collector. Another limitation is the one year statute of limitations, which the Supreme Court ruled in Rotkiske v. Klemm'' (2019) starts tolling from the date of the alleged violation, not from the date the incident was discovered. Criticisms of the FDCPA By consumer groups Some consumer groups argue that the FDCPA does not go far enough, and does not provide sufficient deterrence against unscrupulous collection agencies. Consumer groups have complained that the maximum statutory damages contained in the original 1977 version of the law has not kept up with inflation; $1,000 in 1977 dollars is worth $ as of . By the credit industry Conversely, many in the credit industry and some courts have taken the stance that the FDCPA has often been used to file frivolous lawsuits and seek damages for minor technical violations and has, at times, seriously impeded their ability to collect valid debts. Given the strict liability nature of the FDCPA, the collections industry and the insurance companies that provide liability coverage for them have repeatedly lobbied Congress to relax provisions of the law to reduce their civil exposure for these "hyper-technical" violations. The accounts receivable management industry has also raised concerns that the FDCPA contains contradictions that often lead to liability on the part of collection agencies in civil cases, especially when dealing with technology that did not exist when the law was written. For example, the FDCPA requires a collection agency to identify itself as such in any communication with a consumer. At the same time, a collection agency cannot disclose the debt of a consumer to anyone else. These two requirements are at odds when a collector leaves a message on an answering machine or voicemail system. If the collector identifies himself and his company, a third party could hear the message, thus resulting in a third party disclosure violation. Case law has tackled this issue but has not yet resolved it. Regulatory agencies and the FDCPA For its part, the Federal Trade Commission (FTC) produces an annual report to Congress of its