Conway v. Portfolio Recovery Assocs., LLC, 2014 U.S. Dist. LEXIS 43281 (E.D. Ky. Mar. 31, 2014):
Conway is first case accessible online—state or federal—to reach the issue of the statute of limitations for credit card debts. Conway strongly implies that credit card agreements are not contracts in writing within the meaning of Kentucky’s statute-of-limitations laws. But Conway holds that the debt collector’s cause of action was subject to Virginia’s three-year statute of limitations under a straight forward application of Kentucky’s borrowing statute.