18.  On or about June 17, 2015, Defendant sent a written communication to Plaintiff in  connection with the collection of the Debt. A true and correct copy of the June 17, 2015  communication to Plaintiff is attached hereto as Exhibit A.   19.  The June 17, 2015 communication was the first communication Plaintiff received  from Defendant.   20.  Plaintiff did not receive any additional communications from Defendant within  five days of the June 17, 2015 communication.   21.  The June 17, 2015 communication to Plaintiff stated that Plaintiff’s “above  referenced account(s) have been turned over to our law firm by COMENITY BANK for  collection.” See Ex. A.   22.  Defendant’s June 17, 2015 communication continued, “This communication is  from a debt collector. This is an attempt to collect a debt, and any information obtained will be  used for that purpose.” See Ex. A.   27.  Plaintiff brings this action as a class action pursuant to Federal Rules of Civil  Procedure 23(a) and (b)(3) on behalf of a class consisting of:  (a) All persons with a New Mexico address, (b) to whom Thomason Law  Firm, LLC mailed an initial debt collection communication that stated:  “Unless this account is paid in full within 30 days of the date you receive this  letter, a lawsuit may be filed against you to collect the amount owed,” (c) in  the one year preceding the date of this complaint, (d) in connection with the  collection of a consumer debt.  Excluded from the class is Defendant, its officers and directors, members of their immediate  families and their legal representatives, heirs, successors, or assigns, and any entity in which  Defendant has or had controlling interests.   28.  The proposed class satisfies Rule 23(a)(1) because, upon information and belief, it  is so numerous that joinder of all members is impracticable. The exact number of class members  is unknown to Plaintiff at this time and can only be ascertained through appropriate discovery.  The proposed class is ascertainable in that, upon information and belief, the names and addresses  of all members of the proposed class can be identified in business records maintained by  Defendant.     30.  Plaintiff satisfies Rule 23(a)(4) because she will fairly and adequately protect the  interests of the members of the class and has retained counsel experienced and competent in  class action litigation. Plaintiff has no interests that are contrary to or in conflict with the  members of the class that she seeks to represent.   31.  A class action is superior to all other available methods for the fair and efficient  adjudication of this controversy, since joinder of all members is impracticable.     32.  Furthermore, as the damages suffered by individual members of the class may be  relatively small, the expense and burden of individual litigation make it impracticable for the  members of the Class to individually redress the wrongs done to them. There will be no  difficulty in the management of this action as a class action.   34.  Plaintiff repeats and re-alleges each and every factual allegation contained in  paragraphs 1 through 33.   36.  The manner in which Defendant conveyed the validation notice required by 15  U.S.C. § 1692g was ineffective and overshadowed and contradicted the statutory notice.   37.  Specifically, the June 17, 2015 communication stated: “Unless this account is  paid in full within 30 days of the date you receive this letter, a lawsuit may be filed against you  to collect the amount owed.” This statement conveyed to the least-sophisticated consumer that  the only way to avoid a lawsuit was to make full payment within 30 days, when, in reality, the  consumer could dispute all or a portion of the debt during that 30-day validation window.   38.  The effect of the June 17, 2015 communication was to cause the least- sophisticated consumer to waive, or believe the consumer did not have, the rights afforded under  15 U.S.C. § 1692g.   39.  In addition, Defendant’s June 17, 2015 communication overshadowed and  rendered ineffective the disclosures required by 15 U.S.C. § 1692g.   40.  The language that Defendant included in its June 17, 2015 communication to  Plaintiff contradicts statutorily-mandated disclosures that Defendant was required to provide to  Plaintiff.   41.  In the alternative, Defendant, through its communication, failed to explain an  apparent, though not actual contradiction that its letter creates regarding statutorily-mandated  disclosures that Defendant was required to provide to Plaintiff.   42.  Defendant designed its June 17, 2015 letter to Plaintiff to evade the spirit of the  FDCPA, and to lead Plaintiff to disregard her statutory rights under the FDCPA.   PRACTICES ACT, 15 U.S.C. § 1692g(b)  