55th Management Corp. in New York City owns residential property that it leases to various tenants. In June 2000, claiming that one of the tenants, Leslie Goldman, owed more than $13,000 in back rent, 55th retained Jeffery Cohen, an attorney, to initiate nonpayment proceedings. Cohen filed a petition in New York state court against Goldman, seeking recovery of the unpaid rent and at least $3,000 in attorneys' fees. After receiving notice of the petition, Goldman filed a suit in a federal district court against Cohen. Goldman contended that the notice of the petition constituted an initial contact that, under the Fair Debt Collection Practices Act (FDCPA), required a validation notice at the time, or within five days, of the notice of the petition. Therefore, Goldman argued that Cohen was in violation of the FDCPA. Should the filing of a suit in state court be considered "communication," requiring a debt collector to provide a validation notice under the FDCPA?