10.  Defendant alleges Plaintiff owes a debt (“the Debt”).     11.  The Debt was primarily for personal, family or household purposes and is  therefore a “debt” as defined by 15 U.S.C. § 1692a(5).   12.  Sometime after the incurrence of the Debt, Plaintiff fell behind on payments  owed.    13.  Thereafter, at an exact time known only to Defendant, the Debt was assigned or  otherwise transferred to Defendant for collection.    14.  In its efforts to collect the debt, Defendant contacted Plaintiff by letter (“the  Letter”) dated April 16, 2018. (“Exhibit 1.”)    15.  The Letter was the initial communication Plaintiff received from Defendant.   16.  The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).    17.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.   18.  The written notice must contain the amount of the debt.     19.  The written notice must contain the name of the creditor to whom the debt is  owed.    20.  The written notice must contain a statement that unless the consumer, within  thirty days after receipt of the notice, disputes the validity of the debt, or any portion thereof, the  3  49.  Plaintiff brings this action individually and as a class action on behalf of all  persons similarly situated in the State of New York from whom Defendant attempted to collect a  consumer debt using a collection letter having the same deficiencies as the Letter herein, from  one year before the date of this Complaint to the present.    50.  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.   51.  Defendant regularly engages in debt collection.   52.  The Class consists of more than 35 persons from whom Defendant attempted to  collect delinquent consumer debts using a collection letter having the same deficiencies as the  Letter herein.   53.  Plaintiff's claims are typical of the claims of the Class.  Common questions of law  or fact raised by this class action complaint 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.  This class action is superior to other available methods for the fair and efficient adjudication of  this controversy.   54.  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.   55.  Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class action proposed is not extraordinarily difficult, and the factual and  legal issues raised by this class action complaint 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.  6 