Creditor sought non-dischargeability of credit card debt pursuant to 11 U.S.C. § 523(a)(2)(A). Debtor had been issued a Visa credit card in 1986, which she used regularly. Beginning in early 1989, debtor's credit limit for the card was raised to $2,500, which limit debtor did not exceed prior to July 1989. The balance on debtor's July 9, 1989 Visa bill was approximately $2,200, but that balance had ballooned to more than $11,000 by September 19, 1989, when debtor filed her chapter 7 petition. Purchases made by debtor on July 1, 1989 put her balance over the credit limit, and her purchases thereafter totaled approximately $8,650. When debtor made those purchases, she was insolvent. The court adopted the "implied representation" doctrine, to the effect that credit card purchases include an implied representation that the cardholder has the ability and intention to pay the charge, to conclude that creditor had established that debtor made a materially false representation, upon which creditor relied to its detriment, as required for non-dischargeability by § 523(a)(2)(A). In considering whether creditor had established debtor's intent to deceive, the court sought guidance from factors other courts within the Tenth Circuit had used, concluding that nearly all of those factors supported a finding that debtor intended to deceive creditor. The court additionally found that debtor's demeanor and credibility also supported a finding of intent to deceive. The court concluded that the charges in excess of debtor's credit limit were non-dischargeable under § 523(a)(2)(A), and that creditor was entitled to a non-dischargeable judgment for that amount, plus interest and attorney's fees.