10.  Exhibit A is false, deceptive, and misleading because the letter presents multiple  conflicting interpretations as to whether or not the underlying delinquency will be reported to the  credit bureaus.    12.  By stating that the debt may be reported to the credit bureaus, and then stating that it  would not be reported, Defendant’s letter confuses the consumer concerning whether the debt  will be reported or not.   13.  The letter also confuses the consumer concerning whether the Defendant itself may report  the delinquency to the credit bureaus. While stating in one sentence that the debt may be reported  to the credit bureaus, but that only LVNV will not report it, the least sophisticated consumer is  led to believe, that the account in question may be reported by the Defendant itself. In fact, the  debt is no longer eligible for credit reporting at all.    14.  Another reasonable interpretation of the letter given the proximity of the confusing and  conflicting language is that what Defendant means when it says the current owner may report it  to the credit bureaus, is that the owner just prior to LVNV may report it to the credit bureaus.  Through this interpretation, the least sophisticated consumer reconciles the inherent contradictory  language, leaving the consumer confused as to his or her rights.   B. Interest   15.  Notwithstanding the above, Defendant is attempting to collect a debt against Plaintiff  incurred from the use of a credit card.    16.  Even the least sophisticated is aware that credit card debts accrue interest.    17.  In Exhibit A, Defendant discloses the principal balance obligation in addition to the  interest balance obligation.    19.  Despite Defendant’s choice not to pursue interest, Defendant’s letter deceptively implies  that interest is accruing by making clear that interest is being pursued on the debt.    20.  Upon information and belief, Defendant highlights the “Interest balance” to impart a  sense of urgency to the consumer to pay his or her debts lest interest continue to accrue.   21.  Thus, Defendant’s deceptive language leads to two reasonable interpretations.   22.  On the one hand, the least sophisticated consumer reads Exhibit A and believes that the  balance being sought in the letter is the total and final balance. This interpretation is supported by  Defendant’s failure to disclose that interest is accruing.     23.  On the other hand, the least sophisticated consumer reads Exhibit A and believes that  interest is continuing to accrue given the fact that even the least sophisticated consumer is aware  that credit card debt accrues interest, and by applying this information in the context of  Defendant’s clear indication that interest is accruing by the listing of the “interest balance.”   24.  Disclosing whether or not interest is accruing is in fact material as it directly impacts  whether a consumer will pay their debts. If interest is accruing, a consumer is more likely to pay  their debts before they increase.   25.  Given that Defendant’s letter leads to two reasonable interpretations, at least one of which  is false, Defendant’s letter is false, deceptive, and misleading.   26.  Plaintiff brings this as a class action pursuant to Fed. R. Civ. P. 23.   43.  Plaintiff repeats the allegations contained in the above paragraphs and incorporates them as  if specifically set forth at length herein.   44.  Defendant’s false and deceptive representations to Plaintiff violate the below provisions of  the FDCPA.   46.  Section 1692f provides:   § 1692f. Unfair Practices  A debt collector may not use unfair or unconscionable means to collect or  attempt to collect any debt. . . .  47.  Plaintiff repeats the allegations contained in the above paragraphs and incorporates them as  if specifically set forth at length herein.   48.  Defendant’s collection letter is false and deceptive in violation of numerous provisions of  the FDCPA.    6.  On or about October 18th, 2016, Defendant sent Plaintiff the letter attached as Exhibit A,  in attempt to collect a debt from Plaintiff.    7.  Exhibit A sought to collect a purported credit card debt incurred for personal, family or  household purposes and not for business purposes. Upon information and belief, the underlying  debt is beyond the statute of limitations. Upon information and belief, the underlying debt is over  seven years old, making it ineligible for credit reporting.    8.  Credit card debt has long been considered a “debt” as that term is used and defined within  the FDCPA.    9.  Collection letters within the Second Circuit are viewed from the perspective of the least  sophisticated consumer.   A. Credit Reporting   The Class   VIOLATION OF THE CONNECTICUT UNFAIR TRADE PRACTICES ACT  Conn. Gen. Stat. § 42-110 et seq.    VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692 et seq.   