10.  Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   11.  The Class consists of:   a. all individuals with addresses in the State of New York;  b. to whom Defendant sent a response to a consumer’s dispute;  c. that failed to include billing statements that verified the amount sought by the  Defendant;  d. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (2l) days after the filing of this action.   12.  The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf they attempt to collect and/or have  purchased debts.   13.  Excluded from the Plaintiff Class are the Defendant and all officers, members,  partners, managers, directors and employees of the Defendant and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate  families.    15.  The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiff will fairly and adequately protect the interests of the  Plaintiff Class defined in this complaint. The Plaintiff has retained counsel with experience in  handling consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiff  nor his attorneys have any interests, which might cause them not to vigorously pursue this action.   17.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Class predominate over any questions affecting an individual member, and a class action is  superior to other available methods for the fair and efficient adjudication of the controversy.   18.  Depending on the outcome of further investigation and discovery, Plaintiff may, at  the time of class certification motion, seek to certify a class(es) only as to particular issues  pursuant to Fed. R. Civ. P. 23(c)(4).  20.  Some time prior to March 27, 2021, an obligation was allegedly incurred to creditor  U.S. Bank National Association (hereinafter “U.S. Bank”).   21.  The U.S. Bank obligation arose out of transactions involving personal, family or  household purposes obtained by Plaintiff from U.S. Bank and was incurred primarily for  personal, family or household purposes.    22.  Specifically, Plaintiff allegedly bought goods for personal and/or family use using  his Harley-Davidson Visa Signature Credit Card.    23.  The alleged U.S. Bank obligation is a "debt" as defined by 15 U.S.C.§ 1692a (5).   24.  U.S. Bank is a "creditor" as defined by 15 U.S.C.§ 1692a (4).   25.  Defendant subsequently purchased the defaulted U.S. Bank debt for the purpose of  debt collection. Therefore, Defendant is a “debt collector” as defined by 15 U.S.C.§ 1692a (6).  Violation – March 27, 2021 Collection Letter   26.  On or about March 27, 2021, Defendant sent the Plaintiff a response to a dispute  made by the Plaintiff regarding the alleged debt, originally owed to U.S. Bank (See “Letter”  attached as Exhibit A).   27.  Towards the top right portion of the Letter on page one, it lists in relevant part:  Balance: $20,750.03.   28.  The Letter claims to include documents that establish its “validity,” however the  credit card statement included does not match the balance provided on page one.    30.  The Defendant failed to provide any explanation in page one as to why the balance  increased. The omission of an explanation leaves open several options in the mind of a  consumer; either:   (1) the Defendant failed to include the most recent credit card statement, which potentially  explains the $417.59 increase in the total balance due;   (2) the Defendant made a mistake on the total “balance” of page 1, which would leave the  Plaintiff with a decreased remaining balance due.  (3) the Defendant is charging additional interest or fees to the charge off amount from the  original Creditor.   31.  Therefore, the Letter provided by the Defendant which ostensibly intends to validate  the Plaintiff’s debt has no meaning and serves only to mislead and confuse the consumer as the  true balance cannot be determined from the Letter.   32.  The Plaintiff could not determine the correct amount owed from the Letter because  multiple balances were provided without any explanation for the difference between the  balances.   33.  Plaintiff incurred an informational injury as he could not ascertain from the deceptive  and misleading Letter the total amount he currently owed on the debt.   34.  Further, Defendant’s letter is potentially a false representation of the amount of the  debt due, depending on what motivated Defendant’s total balance – either a mistake, failing to  provide the most recent credit card statement, or charging additional interest or fees.   36.  As a result of Defendant’s false, deceptive, and misleading debt collection practices,  Plaintiff has been damaged.  37.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   38.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   39.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   40.  Defendant violated §1692e :   a. As the Letter is open to more than one reasonable interpretation, at least one of  which is inaccurate in violation of §1692e(2);  b. By making a false and misleading representation in violation of §1692e(10).   41.  By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  