11.  This Action is properly maintained as a class action. The Class is initially defined  as:  All New York consumers for whom Defendant communicated to any person  credit information, which is known to be false and/or for whom Defendant  failed to communicate to any person that a disputed debt was disputed as set  forth herein.  The class definition may be subsequently modified or refined.  The Class  period begins one year prior to the filing of this Action.   12.  The Class satisfies all the requirements of Rule 23 of the FRCP for maintaining a  class action:  a. Numerosity: The Class is so numerous that joinder of all members is  impracticable because there are hundreds and/or thousands of persons who  were sent debt collection letters and/or notices from the Defendant(s) that  violate specific provisions of the FDCPA. Plaintiff is complaining about a  standard conduct that occurred to at least fifty (50) persons. The  undersigned has, in accordance with FRCP Rule 5.2, redacted the financial  account numbers and/or personal identifiers in said letter.  b. Commonality: There are questions of law and fact common to the class  members which predominate over questions affecting any individual Class  member.  These common questions of law and fact include, without  limitation:  i.  Whether the Defendants violated various provisions of the  16.  Plaintiff is at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. § 1692a(3).   17.  Sometime prior to August 21, 2020, Plaintiff allegedly incurred one or more  financial obligations to SPRINT ("OBLIGATION” or “OBLIGATIONS") for which Defendant  reported information to one or more national credit reporting agencies.   18.  Plaintiff allegedly incurred the OBLIGATION in connection with personal use.   19.  The OBLIGATION arose out of a transaction, in which money, property,  insurance or services, which are the subject of the transaction, are primarily for personal, family  or household purposes.   20.  Plaintiff incurred the OBLIGATIONS by obtaining goods and services which  were primarily for personal, family and household purposes.   21.  The OBLIGATION did not arise out of a transaction that was for non-personal  use.   22.  The OBLIGATION did not arise out of a transaction that was for business use.   23.  The OBLIGATION is a "debt" as defined by 15 U.S.C. § 1692a(5).   24.  SPRINT and/or its predecessor is a "creditor" as defined by 15 U.S.C. § 1692a(4).   25.  On or before August 21, 2020, the OBLIGATIONS were referred to ERC for the  purpose of collection.   27.  The August 21, 2020 letter was sent to Defendant in connection with the  collection of the OBLIGATIONS.   28.  The August 21, 2020 letter which was sent to the Defendant stated in part:  RE:  Latisha Cooper  Creditor: SPRINT  Alleged Amount Due: $1,069.00  Please be advised that I dispute the above debt.   29.  After the date of the dispute, Defendant knew or should have known that the  credit information concerning the OBLIGATIONS would be communicated to creditors and  other persons.   30.  The credit information communicated to these creditors and other persons did not  indicate that the OBLIGATIONS were disputed.   31.  The credit information communicated to these creditors and other persons  concerning the OBLIGATIONS was false.   32.   Since August 21, 2020, Defendant has communicated to at least one person,  credit information which is known or should be known to be false.   33.  ERC knew or should have known that its actions violated the FDCPA.   34.  Defendant could have taken the steps necessary to bring its actions within  compliance with the FDCPA, but neglected to do so and failed to adequately review its actions to  ensure compliance with the law.  37.  Plaintiff, on behalf of herself and others similarly situated, repeats and realleges all  prior allegations as if set forth at length herein.   38.  Defendant violated 15 U.S.C. § 1692e of the FDCPA by using any false,  deceptive or misleading representation or means in connection with its attempts to collect debts  from Plaintiff and others similarly situated.   39.  Defendant violated 15 U.S.C. § 1692e of the FDCPA in connection with Plaintiff  and others similarly situated.   40.  By failing to communicate that the OBLIGATION was disputed to one or more of  the credit reporting bureaus, Defendant engaged in a false, deceptive or misleading  representation or means in connection with the collection of the debt.   41.  Defendant violated 15 U.S.C. § 1692e(2)(A) of the FDCPA by falsely  representing the character or legal status of the debt.   43.  By communicating credit information which is known to be false or should be  known to be false, Defendant made a false representation of the character or legal status of the  debt.   44.  Section 1692e(8) of the FDCPA prohibits a debt collector from communicating to  any person credit information which is known to be false or should be known to be false,  including the failure to communicate that a disputed debt is disputed.   45.  Defendant violated 15 U.S.C. § 1692e(8) of the FDCPA by communicating to any  person credit information which is known to be false or should be known to be false.   46.  Defendant violated 15 U.S.C. § 1692e(8) of the FDCPA by failing to  communicate to any person that the OBLIGATION was disputed.   47.  Defendant violated 15 U.S.C. § 1692e(8) of the FDCPA by failing to  communicate to one or more of the credit reporting bureaus that the OBLIGATION was  disputed.   48.  Section 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.   49.  By failing to communicate that the OBLIGATION was disputed as described  herein, Defendant engaged in a false representation or deceptive means to collect or attempt to  collect the debt.   50.  Defendants’ conduct as described herein constitutes unfair or unconscionable  means to collect or attempt to collect any debt.   52.  Plaintiff and others similarly situated have a right to free from abusive debt  collection practices by debt collectors.   53.  Plaintiff and others similarly situated have a right to have the Defendant abide by  its obligations under the FDCPA and those specifically found at 15 U.S.C. § 1692e(8).   54.  Plaintiff and others similarly situated have suffered harm as a direct result of the  abusive, deceptive and unfair collection practices described herein.    55.  Plaintiff has suffered damages and other harm as a direct result of the Defendants’  actions, conduct, omissions and violations of the FDCPA described herein.   FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §   1692 et seq.  VIOLATIONS   