16.  Mr. Golden is a natural person allegedly obligated to pay a debt.    18.  Plaintiffs’ 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, homeowners association fees (the “Debt”).     19.  Defendant uses instrumentalities of interstate commerce or the mails in a business  the principal purpose of which is the collection of any debts.   20.  Defendant regularly collects or attempts to collect, directly or indirectly, debts  owed or due, or asserted to be owed or due, another.   21.  In connection with the collection of the Debt, Defendant sent Plaintiffs written  communication dated April 22, 2020.   22.  A true and correct copy of Defendant’s April 22, 2020 letter is attached as Exhibit  A.   23.  Defendant’s April 22, 2020 letter was its initial communication with Plaintiffs  with respect to the Debt.   24.  Defendant’s letter purported to contain the notices required by 15 U.S.C. §  1692g(a).   25.  However, Defendant’s April 22, 2020 letter stated, in relevant part: “Unless you  dispute the validity of the debt, or any portion, within 30 days after receipt of this letter, the debt  will be assumed to be valid.” Exhibit A.    26.  This statement fails to inform Plaintiff that the Debt will be assumed to be valid  by Defendant.    28.  Upon information and belief, Defendant’s April 22, 2020 letter is based on a form  or template (the “Template”) used to send an initial written communication to a consumer.   29.  Defendant has used the Template to send initial collection notices to at least 40  individuals in the State of North Carolina within the one year prior to the filing of this complaint.   30.  Plaintiffs bring this action on behalf of themselves and all others similarly  situated.  Specifically, Plaintiffs seek to represent the following class:  All individuals with a North Carolina address to whom Defendant sent an initial  collection letter based on the Template, within one year before the date of this  complaint, and in connection with the collection of a debt.   31.  The proposed class specifically excludes the United States of America, the State  of North Carolina, counsel for the parties, the presiding United States District Court Judge, the  Judges of the United States Court of Appeals for the Fourth Circuit, and the Justices of the  United States Supreme Court, all officers and agents of Defendants, and all persons related to  within the third degree of consanguinity or affection to any of the foregoing persons.      32.  The class is averred to be so numerous that joinder of members is impracticable.     33.  The exact number of class members is unknown to Plaintiffs at this time and can  be ascertained only through appropriate discovery.     34.  The class is ascertainable in that the names and addresses of all class members  can be identified in business records maintained by Defendants.     36.  The claims of Plaintiffs are typical of the claims of the class they seek to  represent.   37.  The claims of Plaintiffs and of the class originate from the same conduct, practice,  and procedure on the part of Defendants. Thus, if brought and prosecuted individually, the  claims of each class member would require proof of the same material and substantive facts.     38.  Plaintiffs possess the same interests and have suffered the same injuries as each  class member. Plaintiffs assert identical claims and seeks identical relief on behalf of the  unnamed class members.   39.  Plaintiffs will fairly and adequately protect the interests of the class and have no  interest adverse to or which directly and irrevocably conflicts with the interests of other class  members.   40.  Plaintiffs are willing and prepared to serve this Court and the proposed class.   41.  The interests of Plaintiffs are co-extensive with and not antagonistic to those of  the absent class members.     42.  Plaintiffs have 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 Plaintiffs and all absent class members.     44.  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  class. 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.   45.  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.   46.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(3) in that the  questions of law and fact that are common to members of the class predominate over any  questions affecting only individual members.   47.  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 been 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.  49.  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).     50.  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)).   51.  This validation requirement is a “significant feature” of the law that aimed to  “eliminate the recurring problem of debt collectors dunning the wrong person or attempting to  collect debts which the consumer has already paid.”  See Hernandez v. Williams, Zinman &  Parham PC, 829 F.3d 1068, 1070 (9th Cir. 2016) (citing S. Rep. No. 95-382, at 4 (1977)).   52.  “To comply with the FDCPA’s notice requirements, the notice must actually and  effectively convey to the consumer his right to dispute the debt.”  In re Martinez, 271 B.R. 696,  700 (S.D. Fla. 2001), aff’d, 311 F.3d 1272 (11th Cir. 2002).   VIOLATION OF 15 U.S.C. § 1692g(a)(3)  