 (Violation of the Rosenthal FDCPA)   (Violation of the FDCPA)   18.   Sometime after November 9, 2016, Plaintiff received her first collection  notice dated November 9, 2016 (hereinafter referred to as “Validation Notice”) from  Defendant, attempting to collect a debt in the amount of $10,024.42.  The debt was  allegedly owed to American Express Co.  A copy of the Validation Notice is attached  hereto as Exhibit 1, and is incorporated herein by reference.   19.  Defendant’s Validation Notice does not state that the $10,024.42 debt is  increasing due to accruing interest, late charges, or other fees.  In fact, Defendant’s  Validation Notice is completely devoid of any language that would either confirm or  deny the existence of acquiring interest, late charges, or other fees.   20.  Sometime after December 14, 2016, Plaintiff received a second  collection notice, dated December 14, 2016, from Defendant attempting to collect a  debt in the amount of $10,218.43.  The debt increased from $10,024.42 to  $10,218.43.     21.  Upon information and belief, Defendant was either charging daily  accruing interest, late charges, or other fees, which increased the total amount owed.    22.   Upon information and belief, Defendant’s debt collection practice is  largely automated and utilizes standardized form letters or templates.  23.  Plaintiff brings this action on his own behalf, and on behalf of all others  similarly situated.  40.   Plaintiff re-alleges all paragraphs above, as if fully set forth herein.  41.  Defendant violated 15 U.S.C. section 1692g(a)(1) because its Validation  Notice failed to clearly state the amount of the debt.  Defendant failed to clearly state  the amount of the debt because it failed to disclose that the debt was subject to daily  accruing interest, late charges, or other fees.  It is well established that a debt  collector, who attempts to collect accruing interest, late charges, or other fees on a  debt, must use some type of safe harbor language informing the debtor that the debt  increases due to daily accruing interest, late charges, or other fees.  See Akram v.  California Business Bureau Inc., 2016 WL 7029262 (S.D. Cal. Oct. 3, 2016); Chuway  v. National Action Financial Services, Inc., 362 F.3d 944, 949 (7th Cir. 2004); Miller  v. McCalla, Raymer, Padrick, Cobb, Nichols, & Clark, L.L.C., 214 F.3d 872, 876 (7th  Cir. 2000); Dragon v. I.C. System, Inc., 483 F.Supp.3d 198, 203 (D. Conn. 2007).  46.   Plaintiff re-alleges all paragraphs above, as if fully set forth herein.   47.   Any violation of the FDCPA is a violation of California Civil Code  section 1788.17, also known as the Rosenthal FDCPA, because section 1788.17  incorporates the FDCPA.   48.  Defendant violated Civil Code section 1788.17 because it violated 15  U.S.C. sections 1692e, 1692e(2)(A) and 1692e(10), and 1692g(a)(1), as discussed  above.   49.  The Ninth Circuit has ruled that the Rosenthal FDCPA incorporates the  FDCPA’s class action damages provision in 15 U.S.C. section 1692k(a)(2)(B) via  California Civil Code section 1788.17.  See Gonzales v. Arrow Fin. Servs., LLC, 660  F.3d 1055, 1066 (9th Cir. 2011)     50.  As a result of each and every violation of the Rosenthal FDCPA,  Plaintiff has suffered actual damages and harm resulting from Defendant’s actions as  heretofore alleged, including but not limited to worry, emotional distress, anxiety, and  humiliation, the exact amount of which is to be proven at trial.   51.  As a result of each and every violation of the Rosenthal FDCPA,  Plaintiff incurred additional actual damages including, but not limited to,  transportation and gasoline costs to the law firm, telephone call charges, copies,  postage, and other damages.    