22.  Plaintiff’s alleged obligation arises from a transaction in which the money,  property, insurance, or services that are the subject of the transaction were incurred  primarily for personal, family, or household purposes—namely, a personal automobile  loan (the “Debt”).     23.  Defendant uses instrumentalities of interstate commerce or the mails in a  business the principal purpose of which is the collection of any debts.   24.  Defendant regularly collects or attempts to collect, directly or indirectly,  debts owed or due, or asserted to be owed or due, another.   25.  In connection with the collection of the Debt, Defendant sent Plaintiff a  letter dated January 8, 2018.   26.  A true and correct copy of Defendant’s January 8, 2018 letter is attached to  this complaint as Exhibit A.   27.  Defendant’s January 8, 2018 letter was Defendant’s initial communication  with Plaintiff in connection with the collection of the Debt.    28.  Defendant’s January 8, 2018 letter purported to provide the statements  required by 15 U.S.C. § 1692g(a).   29.  Among the rights provided by 15 U.S.C. § 1692g(a) is a 30-day period  from the consumer’s receipt of the initial communication in which the consumer may  dispute the debt or request verification.   30.  Defendant sent Plaintiff a subsequent letter dated January 29, 2018.   32.  Defendant’s January 29, 2018 letter states, in part:   We have tried to contact you in order to resolve the debt owed by you to  our Client. We want to do so without the need for litigation, but  unfortunately, we still have not heard from you and this matter remains  unresolved.  Unless we hear from you now, we can only assume that you are refusing to  voluntarily address this matter. While it is not our wish to do so, failing to  hear from you, we will be compelled to sue.  Exhibit B.   33.  Defendant’s January 29, 2018 letter further states: “I urge you to contact  my Legal Collection Assistant . . . to make arrangements to pay. . . . Please call now.”  Id.    34.  By threatening imminent legal action and urging Plaintiff to contact  Defendant immediately to make payment arrangements, Defendant overshadowed  Plaintiff’s right to dispute and request verification of the Debt within the 30 day time  period.  35.  Plaintiff repeats and re-alleges all factual allegations above.     36.  Defendant’s January 29, 2018 letter is based on a form or template used by  Defendant to send collection letters (the “Template”).   38.  Defendant regularly sends collection letters based on the Template within  30 days from the initial communication with a consumer, and has done so with respect to  over 40 individuals in Arizona.   39.  The Template overshadows the disclosures required pursuant to 15 U.S.C.  § 1692g(a) during the thirty-day dispute period in the same manner as Defendant did with  Plaintiff above.   40.  Plaintiff brings this action on behalf of herself and all others similarly  situated.  Specifically, Plaintiff seeks to represent the following class of individuals:  All persons with an Arizona address, to whom Defendant sent a letter based  upon the Template, in connection with the collection of a consumer debt,  within one year before the date of this complaint and within 30 days of  having sent an initial communication to such person.   41.  The proposed class specifically excludes the United States of America, the  State of Arizona, counsel for the parties, the presiding United States District Court Judge,  the Judges of the United States Court of Appeals for the Ninth Circuit, and the Justices of  the United States Supreme Court, all officers and agents of Defendant, and all persons  related to within the third degree of consanguinity or affection to any of the foregoing  persons.     42.  The class is averred to be so numerous that joinder of members is  impracticable.     44.  The class is ascertainable in that the names and addresses of all class  members can be identified in business records maintained by Defendant.    45.  There exists a well-defined community of interest in the questions of law  and fact involved that affect the parties to be represented. These common questions of  law and fact predominate over questions that may affect individual class members. Such  issues include, but are not limited to: (a) the existence of Defendant’s identical conduct  particular to the matters at issue; (b) Defendant’s violations of the FDCPA; (c) the  availability of statutory penalties; and (d) attorneys’ fees and costs.     46.  Plaintiff’s claims are typical of those of the class she seeks to represent.     47.  The claims of Plaintiff and of the class originate from the same conduct,  practice, and procedure on the part of Defendant. Thus, if brought and prosecuted  individually, the claims of the members of the class would require proof of the same  material and substantive facts.   48.  Plaintiff possesses the same interests and has suffered the same injuries as  each class member. Plaintiff asserts identical claims and seeks identical relief on behalf  of the unnamed class members.     49.  Plaintiff will fairly and adequately protect the interests of the class and has  no interests adverse to or which directly and irrevocably conflict with the interests of  other members of the class.   50.  Plaintiff is willing and prepared to serve this Court and the proposed class.     52.  Plaintiff has retained the services of counsel who are experienced in  consumer protection claims, as well as complex class action litigation, will adequately  prosecute this action, and will assert, protect and otherwise represent Plaintiff and all  absent class members.     53.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(1)(A) and  23(b)(1)(B). The prosecution of separate actions by individual members of the class  would, as a practical matter, be dispositive of the interests of other members of the class  who are not parties to the action or could substantially impair or impede their ability to  protect their interests.     54.  The prosecution of separate actions by individual members of the class  would create a risk of inconsistent or varying adjudications with respect to individual  members of the class, which would establish incompatible standards of conduct for the  parties opposing the classes. Such incompatible standards of conduct and varying  adjudications, on what would necessarily be the same essential facts, proof and legal  theories, would also create and allow the existence of inconsistent and incompatible  rights within the class.     55.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(2) in that  Defendant has acted or refused to act on grounds generally applicable to the class,  making final declaratory or injunctive relief appropriate.   57.  Moreover, a class action is superior to other methods for the fair and  efficient adjudication of the controversies raised in this Complaint in that: (a) individual  claims by the class members will be impracticable as the costs of pursuit would far  exceed what any one plaintiff or class member has at stake; (b) as a result, very little  litigation has commenced over the controversies alleged in this Complaint and individual  members are unlikely to have an interest in prosecuting and controlling separate  individual actions; and (c) the concentration of litigation of these claims in one forum  will achieve efficiency and promote judicial economy.  58.  Plaintiff repeats and re-alleges each factual allegation contained above.   59.  A key provision of the FDCPA is § 1692g, which requires a debt collector  to send, within five days of its initial communication with a consumer, a written notice  which provides information regarding the debt and informs the consumer of his or her  right to dispute the validity of the debt, and/or request the name and address of the  original creditor, within 30 days of receipt of the notice.  See 15 U.S.C. § 1692g(a).     60.  Congress adopted “the debt validation provisions of section 1692g” to  guarantee that consumers would receive “adequate notice” of their rights under the  FDCPA. Wilson v. Quadramed Corp., 225 F.3d 350, 354 (3d Cir. 2000) (citing Miller v.  Payco–General Am. Credits, Inc., 943 F.2d 482, 484 (4th Cir. 1991)).   62.  “The statute is not satisfied merely by inclusion of the required debt  validation notice; the notice Congress required must be conveyed effectively to the  debtor.  It must be large enough to be easily read and sufficiently prominent to be  noticed—even by the least sophisticated debtor.”  Gostony v. Diem Corp., 320 F. Supp.  2d 932, 938 (D. Ariz. 2003); (citing Ost v. Collection Bureau, Inc., 493 F. Supp. 701, 703  (D.N.D. 1980) (“communication must not be designed to ‘evade the spirit of the notice  statute, and mislead the debtor into disregarding the notice’”).   63.  To ensure debt collectors’ notices meaningfully convey consumers’ rights  under § 1692g, Congress has further declared that “[a]ny collection activities and  communication during the 30-day period may not overshadow or be inconsistent with the  disclosure of the consumer’s right to dispute the debt or request the name and address of  the original creditor.”  Id.   64.  If a consumer requests validation, “the debt collector shall cease collection  of the debt . . . until the debt collector obtains verification” and mails such verification to  the consumer. 15 U.S.C. § 1692g(b).   66.  One way in which a debt collection letter can overshadow the notice of  rights under § 1692g is by threatening suit within the 30-day period.   67.  While a debt collector may legally initiate suit before the expiration of the  30-day period, a debt collection notice violates § 1692g where such threats would cause  an unsophisticated consumer to overlook or ignore his or her rights.    68.  To assist debt collectors who wish to threaten suit in collection notices,  Judge Posner has drafted “safe harbor” language—adopted by courts around the nation— that explains the apparent contradiction between the consumer’s right to dispute within  30 days and the debt collector’s right to bring suit before the expiration of that period,  which reads, in relevant part, as follows:  The law does not require me to wait until the end of the  thirty-day period before suing you to collect this debt. If,  however, you request proof of the debt or the name and  address of the original creditor within the thirty-day period  that begins with your receipt of this letter, the law requires me  to suspend my efforts (through litigation or otherwise) to  collect the debt until I mail the requested information to you.  Bartlett v. Heibl, 128 F.3d 497, 502 (7th Cir. 1997).   69.  Where a collection letter makes no effort to explain that the consumer may  take advantage of his or her rights under § 1692g, notwithstanding the threat to file a  lawsuit within the 30-day dispute period, the debt collector runs the risk of violating §  1692g(b).   VIOLATION OF 15 U.S.C. § 1692g(b)  