10. On October 12, 2011,  Northland Group, Inc., sent plaintiff the letter attached as Exhibit A.  11. Exhibit A sought to collect a purported consumer debt incurred for personal, family or household purposes, and not for business purposes.  12. The debt went into default, and the last payment was made,  more than six years prior to the date of the letter.  13. The statute of limitations on a contract in Michigan is six years.  14. Northland regularly attempts to collect debts on which the statute of limitations has expired.  15. Nothing in Exhibit A disclosed that the debt was barred by the statute of limitations.  16. Nothing in Exhibit A disclosed the date of the transactions giving rise to the claimed debt.  18. It is the policy and practice of Northland to send letters seeking to collect time-barred debts that do not disclose the dates of the transactions giving rise to the debts.  19. The Federal Trade Commission has determined  that  “Most consumers do not know their legal rights with respect to collection of old debts past the statute of limitations.... When a collector tells a consumer that she owes money and demands payment, it may create the misleading impression that the collector can sue the consumer in court to collect that debt.”   (http://www.ftc.gov/opa/2012/01/asset.shtm)  The FTC entered into a consent decree with Asset Acceptance, one of the largest debt buyers in the United States, requiring that it disclose to consumers when it is attempting to collect debts that are barred by the statute of limitations.  United States v. Asset Acceptance LLC, Case No. 8 : 12 CV 182 T 27 EAJ (M.D.Fla.). 24. Plaintiff brings this claim on behalf of a class pursuant to Fed.R.Civ.P. 23(a) and 23(b)(3).    25. The class consists of all individuals in Michigan to whom Northland Group, Inc. sent a letter seeking to collect a debt, which debt was a consumer debt on which the last payment had been made more than six years prior to the letter, and which letter was sent on or after a date one year prior to the filing of this action and on or before a date 20 days after the filing of this action.  26. On information and belief, the class is so numerous that joinder of all members is not practicable.  27. There are questions of law and fact common to the class members, which predominate over any questions relating to individual class members.  The predominant common questions are (a) whether defendant attempts to collect time-barred debts without disclosure of that fact and (b) whether such practice violates the FDCPA.  28. Plaintiff’s claim is typical of the claims of the class members.  All are based on the same factual and legal theories.  29. Plaintiff will fairly and adequately represent the class members. Plaintiff  has retained counsel experienced in class actions and FDCPA litigation. 