This is a Consumer Protection Act case. The primary issue presented is whether the collection of debts arising from sales of goods and services is subject to the provisions of the Idaho Consumer Protection Act (the Act), I.C. §§ 48-601 through -619. We hold that the collection of these debts is subject to the provisions of the Act, even when the debts have been sold to a third party by the seller and the collection is by the third party.
We also hold that the attorney general is not required personally to sign an investigative demand issued by his office pursuant to I.C. § 48-611, but that it may be signed by a deputy attorney general.
I.
THE BACKGROUND AND PRIOR PROCEEDINGS.
Western Acceptance Corporation, Inc. (WAC) is in the business of purchasing *400past due accounts receivable and dishonored checks from merchants. In June 1988 Donald P. Christensen, president of WAC, received an investigative demand issued in the name of the attorney general of the state of Idaho requesting information concerning the activities of Christensen, personally, and WAC in demanding, requesting or obtaining payments from thirty-six individuals in 1985, 1986, 1987 and 1988. WAC and Christensen filed a petition in district court to set aside or modify the investigative demand. As it relates to this appeal, the petition alleged that (1) the investigative demand had not been executed by the attorney general as required by the Act because it was signed by a special deputy attorney and (2) the activities of WAC and Christensen were not subject to the Act, since they were not engaged in advertising, offering for sale, selling, or distributing any goods or services directly or indirectly affecting the people of the state of Idaho.
The trial court ruled that there was no showing that the attorney general lacked the authority to appoint deputies to carry out the duties of the attorney general and that “debt collection, in whatever guise,” is subject to the provisions of the Act. WAC and Christensen appealed these rulings.
II.
THE ATTORNEY GENERAL IS NOT REQUIRED TO SIGN AN INVESTIGATIVE DEMAND PERSONALLY.
WAC and Christensen assert that the Act requires the attorney general to sign an investigative demand personally, not through a deputy. We disagree.
I.C. § 48-611(1) provides that when the attorney general has probable cause to believe that a person has done, or is about to do, something that is declared to be unlawful by the Act, the attorney general “may execute in writing” an investigative demand requiring any person who is believed to have information relevant to the alleged or suspected violation to appear and testify or to produce the information. We do not interpret this provision to require the attorney general to sign the investigative demand personally.
I.C. § 67-1401 sets forth an extensive list of duties “of the attorney general.” To require the attorney general personally to perform all of these duties would make the job of the attorney general an impossible one. One of these duties is “[t]o attend the supreme court and prosecute or defend all causes to which the state or any officer thereof, in his official capacity, is a party.” I.C. § 67-1401(1) (1989). This Court has held that a notice of appeal in a case in which an officer of the state is a party does not have to be signed by the attorney general personally. Caesar v. Williams, 84 Idaho 254, 371 P.2d 241 (1962). The authority given to the attorney general under I.C. § 48-611 to issue an investigative demand is not sufficiently different to require the personal signature of the attorney general. In each case the attorney general has the power to act. In neither case does the legislation granting the authority indicate that the action must be taken by the attorney general personally.
WAC and Christensen contend that the authority to issue an investigative demand amounts to the delegation to the attorney general of a quasi-judicial function and that the issuance of the demand should require the signature of the attorney general for that reason. However, I.C. § 48-611(2) provides an immediate means for judicial intervention to extend the return date, or to modify or set aside the demand. Therefore, the demand does not constitute an unqualified power of the attorney general to require the presentation of the information sought. We see nothing in this formulation of the authority of the attorney general that causes us to believe that the legislature intended that the attorney general personally is required to sign the demand. If such a unique requirement were intended, we believe the legislation requiring it should be more specific than I.C. § 48-611(1).
III.
THE COLLECTION OF A DEBT ARISING FROM THE SALE OF GOODS OR SERVICES IS SUBJECT TO THE PROVISIONS OF THE ACT.
WAC and Christensen assert that their activities do not constitute “trade or *401commerce” as defined in the Act and that they are, therefore, not subject to the provisions of the Act. We disagree.
The acts or practices that are unlawful under the Act are only those that are “in the conduct of any trade or commerce.” I.C. § 48-603 (1977). “Trade” and “commerce” are defined by the Act to mean “the advertising, offering for sale, sale, or distribution of any goods or services, directly or indirectly affecting the people of this state.” I.C. § 48-602(2) (1977). Our task here is to determine whether the legislature intended by this definition to include the collection of debts arising out of the sale of goods or services.
The legislature indicated that in construing the Act “due consideration and great weight shall be given to the interpretation of the federal trade commission and the federal courts relating to section 5(a)(1) of the federal trade commission act (15 U.S.C. § 45(a)(1)).” I.C. § 48-604(1). We believe this direction indicates the intent of the legislature that the Act be liberally construed to effect the legislative intent “to deter deceptive or unfair trade practices and to provide relief for consumers exposed to proscribed practices.” State ex rel. Kidwell v. Master Distribs. Inc., 101 Idaho 447, 455, 615 P.2d 116, 124 (1980). We note that the federal trade commission has for many years interpreted 15 U.S.C. § 45(a)(1) to include debt collection. 16 C.F.R. § 237 (1989) (originally adopted in 1967); State Credit Ass’n, 86 F.T.C. 502 (1975); American Credit Bureau, Inc., 84 F.T.C. 1582 (1974); Sunshine Art Studios, Inc., 81 F.T.C. 836 (1972); Wilson Chem. Co., 64 F.T.C. 168 (1964).
Construing the Act liberally in the manner the legislature indicated we should, we conclude that the collection of a debt arising out of a sale of goods or services is subject to the provisions of the Act, even when the collection of the debt is by a third party who has purchased the debt from the seller. It is the sale that brings the debt into existence that is the crucial event. Debts that do not arise out of the sale of goods and services subject to the provisions of the Act are not covered.
IV.
THE ATTORNEY GENERAL IS NOT ENTITLED TO ATTORNEY FEES FOR DEFENDING THIS APPEAL.
The attorney general asserts that we should award attorney fees for defending this appeal under I.C. § 48-608(3) or I.C. § 12-121. We disagree.
I.C. § 48-608(1) provides that a person who purchases or leases goods or services and thereby suffers loss of money or property as a result of a method, act or practice declared unlawful by the Act may bring an action in district court to recover damages. I.C. § 48-608(3) directs the court to award attorney fees to a prevailing plaintiff in the action and authorizes the court in its discretion to award attorneys fees to a prevailing defendant, “if it finds that the plaintiffs action is spurious or brought for harassment purposes only.” This statute has no application to this action, which was initiated by a petition pursuant to I.C. § 48-611(2) to modify or set aside an investigative demand.
Under I.C. § 12-121 we will award attorney fees to a prevailing party in an appeal in a civil action where the appeal is brought or defended frivolously, unreasonably or without foundation. Minich v. Gem State Developers, Inc., 99 Idaho 911, 918, 591 P.2d 1078, 1085 (1979). Here, the appeal has presented significant issues about which there are legitimate differences of opinion. Although we have resolved the issues in favor of the attorney general, this is not an appropriate case in which to award attorney fees.
V.
CONCLUSION.
We affirm the decision of the trial court that the debt collection in which WAC was engaged that was the subject of the investigative demand by the attorney general is within the definition of trade or commerce under the Act and that the attorney is not required to personally sign the demand.
*402We award costs to the attorney general but no attorney fees on appeal.
BISTLINE, BOYLE and McDEVITT, JJ., concur. BAKES, C.J., concurs in Parts I and II.