In Townsend v Quantum3 Group, LLC (535 BR 415 [Bankr MD Fla 2015]), for example, the court held that a proof of claim filed by a creditor in a bankruptcy proceeding constitutes a "formal pleading" within the meaning of 15 USC § 1692e (11). In support of that holding the Townsend court canvassed authority demonstrating that the bankruptcy proof of claim is a pleading because it is tantamount to the complaint in a civil action:
" '[C]ourts routinely recognize that the filing of a proof of claim is analogous to the filing of a complaint and that, by doing so, a creditor submits itself to the jurisdiction of the court, at least with regard to the adjudication of its claim.' In re Franchi, 451 B.R. 604, 607 (Bankr.S.D.Fla.2011); see O'Neill v. Cont'l Airlines, Inc., . . . 928 F.2d 127, 129 (5th Cir.1991) ('[T]he filing of a proof of claim is analogous to the filing of a complaint in a civil action, with the bankrupt's objection the same as the answer.') . . . ; see also Nortex Trading Corp. v. Newfield, 311 F.2d 163, 164 (2d Cir.1962) ('The filing by Nortex of its proof of claim is analogous to the commencement of an action within the bankruptcy proceeding'.) . . . ; In re Cerrato, 504 B.R. 23, 38 (Bankr. E.D.N.Y.2014) ('The filing of a proof of claim is equivalent to the filing of a complaint in a civil action, and an objection to a claim is analogous to an answer.'). . . .