16.  Defendant regularly collects or attempts to collect debts asserted to be owed to  others.     17.  Defendant is regularly engaged, for profit, in the collection of debts allegedly owed  by consumers.    18.  The principal purpose of Defendant's business is the collection of such debts.   19.  Defendant uses the mails in its debt collection business.   20.  Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6).    21.  Defendant alleges Plaintiff owes a debt (“the alleged Debt”).     22.  The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of a  transaction in which the money, property, insurance, or services which are the subject of the  transaction are primarily for personal, family, or household purposes.   23.  The alleged Debt does not arise from any business enterprise of Plaintiff.   25.  At an exact time known only to Defendant, the alleged Debt was assigned or  otherwise transferred to Defendant for collection.    26.  At the time the alleged Debt was assigned or otherwise transferred to Defendant for  collection, the alleged Debt was in default.   27.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff by calls to  Plaintiff's telephone.   28.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff by letters  including the letter dated June 24, 2020 (the “Letter”). (A true and accurate copy is annexed hereto  as Exhibit 1).   29.  The Letter was the initial written communication Plaintiff received from Defendant  concerning the alleged Debt.   30.  The Letter conveyed information regarding the alleged Debt.   31.  The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).    32.  The Letter was received and read by Plaintiff.   33.  15 U.S.C. § 1692g protects Plaintiff's concrete interests. Plaintiff has the interest  and right to receive a clear, accurate and unambiguous validation notice, which allows a consumer  to confirm that he or she owes the debt sought to be collected by the debt collector. As set forth  herein, Defendant deprived Plaintiff of this right.   34.  15 U.S.C. § 1692e protects Plaintiff's concrete interests. Plaintiff has the interest  and right to be free from deceptive and/or misleading communications from Defendant. As set  forth herein, Defendant deprived Plaintiff of this right.   35.  Plaintiff's injury is “particularized” and “actual” in that the letter that caused the  injury was addressed and sent to Plaintiff specifically.    36.  Plaintiff's injury is directly traceable to Defendant's conduct, because Defendant  sent the Letter.    37.  A favorable judicial resolution of Plaintiff's case would redress Plaintiff's injury  with damages.    38.  The deprivation of Plaintiff's rights will be redressed by a favorable decision herein.     39.  Plaintiff has been misled by Defendant's actions.    41.  Plaintiff justifiably fears that, absent this Court's intervention, Defendant will  ultimately cause her unwarranted economic harm.   42.  As a result of Defendant's conduct, Plaintiff was forced to hire counsel and  therefore has incurred damages including reasonable attorneys' fees in reviewing Plaintiff's rights  under the law and prosecuting this claim.   43.  As a result of Defendant's conduct, Plaintiff's counsel was forced to expend time  and money to investigate the enforceability of the Debt.   44.  Upon information and belief, Plaintiff can prove that all actions taken by Defendant  as described in this Complaint were taken willfully, with either the desire to harm Plaintiff with  knowledge that its actions would very likely harm Plaintiff, and/or with knowledge that its actions  were taken in violation of the law.   45.  15 U.S.C. § 1692e provides, generally, that a debt collector may not use any false,  deceptive, or misleading representation or means in connection with the collection of any debt.   46.  15 U.S.C. § 1692e(2)(A) prohibits the false representation of the character, amount,  or legal status of any debt.   47.  15 U.S.C. § 1692e(3) prohibits a debt collector from using the false representation  or implication that any individual is an attorney or that any communication is from an attorney.   48.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     49.  A debt collection practice can be a “false, deceptive, or misleading” practice in  violation of 15 U.S.C. § 1692e even if it does not fall within any of the subsections of 15 U.S.C. §  1692e.     50.  A collection letter violates 15 U.S.C. § 1692e if, in the eyes of the least  sophisticated consumer, it is open to more than one reasonable interpretation, at least one of which  is inaccurate.    51.  A collection letter also violates 15 U.S.C. § 1692e if it is reasonably susceptible to  an inaccurate reading by the least sophisticated consumer.     52.  The Letter is on the letterhead of the law firm Tenaglia & Hunt.   54.  The least sophisticated consumer would likely assume that a law firm's letterhead  on a collection letter means that the letter is from the law firm.     55.  The least sophisticated consumer would likely assume that a law firm's letterhead  on a collection letter means that the alleged Debt was assigned to the law firm.     56.  The least sophisticated consumer would likely assume that a law firm's letterhead  on a collection letter means that the letter is from an attorney.     57.  The least sophisticated consumer would likely assume that the attorney has been  genuinely involved in the review of Plaintiff's alleged Debt prior to the letter being sent.     58.  The least sophisticated consumer would likely assume that the attorney has been  meaningfully involved in the review of Plaintiff's alleged Debt prior to the letter being sent.     59.  The least sophisticated consumer would likely assume that the attorney has been  personally involved in the review of Plaintiff's alleged Debt prior to the letter being sent.     60.  The least sophisticated consumer would likely assume that the attorney determined  that the letter should be sent.   61.  As such, the least sophisticated consumer would likely feel threatened.   62.  As such, the least sophisticated consumer would likely feel intimidated.   63.  As such, the least sophisticated consumer would likely believe he or she would be  sued by Defendant.   64.  As such, the least sophisticated consumer would likely believe he or she would be  sued by a law firm acting as a debt collector.    65.  As such, the least sophisticated consumer would likely believe he or she would be  sued by Defendant if he or she did not pay the debt.   66.  However, no attorney with Defendant sent the Letter to Plaintiff.     67.  No attorney with Defendant was genuinely involved in the review of Plaintiff's  alleged Debt prior to the Letter being sent to Plaintiff.     68.  No attorney with Defendant was meaningfully involved in the review of Plaintiff's  alleged Debt prior to the Letter being sent to Plaintiff.     69.  No attorney with Defendant was personally involved in the review of Plaintiff's  alleged Debt prior to the Letter being sent to Plaintiff.   71.  The Letter fails to provide any disclaimer such as “Please be advised that we are  acting in our capacity as a debt collector and at this time, no attorney with our law firm has  personally reviewed the particular circumstances of your account.” Greco v. Trauner, Cohen &  Thomas, LLP, 412 F.3d 360, 364 (2005).   72.  The least sophisticated consumer would likely be misled to believe that an attorney  was genuinely involved in the review of Plaintiff's alleged Debt prior to the Letter being sent to  Plaintiff.     73.  The least sophisticated consumer would likely be misled to believe that an attorney  was meaningfully involved in the review of Plaintiff's alleged Debt prior to the Letter being sent  to Plaintiff.     74.  The least sophisticated consumer would likely be misled to believe that an attorney  was personally involved in the review of Plaintiff's alleged Debt prior to the Letter being sent to  Plaintiff.     75.  The least sophisticated consumer would likely be misled to believe that an attorney  determined that the letter should be sent.   76.  Defendant's conduct is a false representation made in connection with the collection  of the alleged Debt in violation of 15 U.S.C. § 1692e.   77.  Defendant's conduct is a deceptive representation made in connection with the  collection of the alleged Debt in violation of 15 U.S.C. § 1692e.   78.  Defendant's conduct is a false representation of the legal status of the alleged Debt  in violation of 15 U.S.C. § 1692e(2)(A).   79.  Defendant's conduct is a false representation that the Letter was from an attorney  in violation of 15 U.S.C. § 1692e(3).   80.  Defendant's conduct is a false implication that the Letter was from an attorney in  violation of 15 U.S.C. § 1692e(3).     81.  Defendant's conduct is a false representation made in an attempt to collect the  alleged Debt in violation of 15 U.S.C. § 1692e(10).   82.  Defendant's conduct is a is a deceptive means in an attempt to collect the alleged  Debt in violation of 15 U.S.C. § 1692e(10).   84.  Plaintiff brings this action individually and as a class action on behalf of all persons  similarly situated in the State of New York.   85.  Plaintiff seeks to certify the following class:   86.  All consumers to whom Defendant sent a collection letter substantially and  materially similar to the Letter sent to Plaintiff, which Letter was sent on or after a date one year  prior to the filing of this action to the present.   87.  This action seeks a finding that Defendant's conduct violates the FDCPA, and asks  that the Court award damages as authorized by 15 U.S.C. § 1692k.   88.  The Class consists of more than thirty-five persons.   89.  Plaintiff's claims are typical of the claims of the Class.  Common questions of law  or fact raised by this action affect all members of the Class and predominate over any individual  issues.  Common relief is therefore sought on behalf of all members of the Class.  A class action  is superior to other available methods for the fair and efficient adjudication of this controversy.   90.  The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of the  Class, and a risk that any adjudications with respect to individual members of the Class would, as  a practical matter, either be dispositive of the interests of other members of the Class not party to  the adjudication, or substantially impair or impede their ability to protect their interests.  Defendant  has acted in a manner applicable to the Class as a whole such that declaratory relief is warranted.   91.  Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class is not extraordinarily difficult, and the factual and legal issues raised  by this action will not require extended contact with the members of the Class, because Defendant's  conduct was perpetrated on all members of the Class and will be established by common proof.   Moreover, Plaintiff has retained counsel experienced in actions brought under consumer protection  laws. 