12.  Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   13.  The Class consists of:   a. all individuals with addresses in the State of Texas;  b. to whom Merchants’ Credit Guide Co. sent a collection letter attempting to  collect a consumer debt;  c. regarding collection of a debt;  d. that failed to properly identify and name the current creditor to whom the debt  was allegedly owed;   e. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (2l) days after the filing of this action.   14.  The identities of all class members are readily ascertainable from the records of  Defendants and those companies and entities on whose behalf they attempt to collect and/or  have purchased debts.   15.  Excluded from the Plaintiff Classes are the Defendants and all officers, members,  partners, managers, directors and employees of the Defendants and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate  families.    16.  There are questions of law and fact common to the Plaintiff Classes, which common  issues predominate over any issues involving only individual class members. The principal issue  is whether the Defendants' written communications to consumers, in the forms attached as  Exhibits A, violate 15 U.S.C. §§ l692e, 1692f and 1692g.   17.  The Plaintiffs' claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiffs will fairly and adequately protect the interests of the  Plaintiff Classes defined in this complaint. The Plaintiffs have retained counsel with experience  in handling consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiffs  nor their attorneys have any interests, which might cause them not to vigorously pursue this  action.   18.  This action has been brought, and may properly be maintained, as a class action  pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure because there is a  well-defined community interest in the litigation:  a. Numerosity: The Plaintiffs are informed and believe, and on that basis allege,  that the Plaintiff Classes defined above are so numerous that joinder of all  members would be impractical.  b. Common Questions Predominate: Common questions of law and fact exist as  to all members of the Plaintiff Classes and those questions predominance over  any questions or issues involving only individual class members. The principal  issue is whether the Defendants' written communications to consumers, in the  forms attached as Exhibit A violate 15 § l692e and §1692f and § 1692g.  c. Typicality: The Plaintiff’s claims are typical of the claims of the class members.  The Plaintiffs and all members of the Plaintiff Classes have claims arising out of  the Defendants' common uniform course of conduct complained of herein.  d. Adequacy: The Plaintiffs will fairly and adequately protect the interests of the  class members insofar as Plaintiffs have no interests that are adverse to the absent  class members. The Plaintiffs are committed to vigorously litigating this matter.  Plaintiffs have also retained counsel experienced in handling consumer lawsuits,  complex legal issues, and class actions. Neither the Plaintiffs nor their counsel  have any interests which might cause them not to vigorously pursue the instant  class action lawsuit.  e. Superiority: A class action is superior to the other available means for the fair  and efficient adjudication of this controversy because individual joinder of all  members would be impracticable. Class action treatment will permit a large  number of similarly situated persons to prosecute their common claims in a single  forum efficiently and without unnecessary duplication of effort and expense that  individual actions would engender.   19.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Classes predominate over any questions affecting an individual member, and a class action is  superior to other available methods for the fair and efficient adjudication of the controversy.   20.  Depending on the outcome of further investigation and discovery, Plaintiffs may, at  the time of class certification motion, seek to certify a class(es) only as to particular issues  pursuant to Fed. R. Civ. P. 23(c)(4).  21.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   22.  Some time prior to January 9, 2017, an obligation was allegedly incurred by the  Plaintiff.   23.  The alleged obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   24.  Illinois Emergency Medical Specialists contracted the Defendant to collect the  alleged debt as referenced on the collection leter as “Our Client.” See January 9, 2017  Collection Letter – Attached hereto as Exhibit A.   25.  Defendant collects and attempts to collect debts incurred or alleged to have been  incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and internet.  Violation I – January 9, 2017 Collection Letter   26.  On or about January 9, 2017, Defendant sent the Plaintiff a collection letter (the  “Letter”).  See January 9, 2017 Collection Letter – Attached hereto as Exhibit A.   27.  This letter did not contain all the requirements of the ‘‘G Notice'' as required by 15  U.S.C. §1692g. Specifically, this letter deceptively fails to identify who the original or current  creditor is to whom the alleged debt is owed.   28.  The letter lists Illinois Emergency Medical Specialists as “Our Client” but nowhere  does the letter clearly identify who the current creditor is as is required by the FDCPA.   29.  It is deceptive to not clearly state who the creditor is in any collection letter sent to a  consumer.   30.  Mere illusions are not enough, but the letter must specifically and clearly state who  the creditor is.   31.  Defendant has failed to provide the consumer with a proper initial communication  letter by failing to clearly identify the original and current creditors of the debt.   32.  As a result of Defendant’s deceptive misleading and false debt collection practices,  Plaintiff has been damaged.  33.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   34.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   35.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   36.  Defendant violated said section by:   a. Making a false and misleading representation in violation of §1692e(10).   37.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  43.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   44.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692g.   45.  Pursuant to 15 U.S.C. §1692g, a debt collector must notify the consumer of the name  of the creditor to whom the debt is owed. §1692g(a)(2).   46.  This notice must be clearly conveyed so that the consumer is clearly advised as to  whom the alleged debt is owed.   47.  Defendant violated this section by unfairly failing to advise Plaintiff as to the identity  of the current creditor who was attempting to collect a debt from her.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C.  §1692g et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  