1. The amount of the debt;   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 New York;  b. to whom Defendant Advanced sent an initial collection letter attempting to  collect a consumer debt;  c. and in response a consumer called up the Defendant to dispute the validity of  the debt;  d. and the Defendant denied the dispute request, specifically demanding a reason  for the dispute;   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 Class are the Defendants and all officer, 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 Class, which common  issues predominate over any issues involving only individual class members. The principal  issue is whether the Defendant’s rejection of the Plaintiffs oral dispute, violated 15 U.S.C.  §1692g.   17.  The Plaintiff’s claims are typical of the class members, as all are based upon the  same facts and legal theories. The Plaintiff will fairly and adequately protect the interests of  the Plaintiff Class defined in this complaint. The Plaintiff has retained counsel with experience  in handling consumer lawsuits, complex legal issues, and class actions, and neither the  Plaintiff nor her 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 Plaintiff is informed and believes, and on that basis alleges,  that the Plaintiff Class defined above is 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 Class and those questions predominance over  any questions or issues involving only individual class members. The principal  issue is whether the Defendant’s rejection of the Plaintiffs oral dispute, violated  15 U.S.C. §1692g.  c. Typicality: The Plaintiff’s claims are typical of the claims of the class  members. The Plaintiff and all members of the Plaintiff Class have claims  arising out of the Defendant’s common uniform course of conduct complained  of herein.  d. Adequacy: The Plaintiff will fairly and adequately protect the interests of the  class members insofar as Plaintiff has no interests that are adverse to the absent  class members. The Plaintiff is committed to vigorously litigating this matter.  Plaintiff has also retained counsel experienced in handling consumer lawsuits,  complex legal issues, and class actions. Neither the Plaintiff nor her counsel has  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  Class 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.   2. The name of the creditor to whom the debt is owed;   20.  Depending on the outcome of further investigation and discovery, Plaintiff 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 November 2, 2018, an obligation was allegedly incurred to  Synchrony Bank.   23.  The Synchrony Bank obligation arose out of transactions to purchase items which  were primarily for personal, family or household purposes.   24.  The alleged Synchrony Bank obligation is a “debt” as defined by 15 U.S.C. §  1692a(5).   25.  Synchrony Bank is a “creditor” as defined by 15 U.S.C. § 1692a(4).   26.  Synchrony Bank or a subsequent owner of the debt contracted the Defendant to  collect the alleged debt.   27.  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 Service, telephone and internet.  Phone Call Violation   28.  On or about November 2, 2018, Defendant sent the Plaintiff an initial contact  notice (the “Letter”) regarding the alleged debt.   29.  When a debt collector solicits payment from a consumer, it must, within five days  of an initial communication notify the consumer in writing of:  (1) the amount of the debt;  (2) the name of the creditor to whom the debt is owed;  (3) 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 debt will be assumed to be  valid by the debt collector;  (4) a statement that if the consumer notifies the debt collector in writing within the thirty- day period that the debt, or any portion thereof, is disputed, the debt collector will obtain  verification of the debt or a copy of the judgment against the consumer and a copy of such  verification or judgment will be mailed to the consumer by the debt collector; and  (5) a statement that, upon the consumer’s written request within the thirty-day period, the  debt collector will provide the consumer with the name and address of the original creditor,  if different from the current creditor. 15 U.S.C. § 1692g(a).  This is commonly known as “the G-Notice”.   3. 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  debt will be assumed to be valid by the debt-collector;   30.  The FDCPA further provides that ‘‘if the consumer notifies the debt collector in  writing within the thirty day period . . . that the debt, or any portion thereof, is disputed . . . the  debt collector shall cease collection . . . until the debt collector obtains verification of the  debt . . . and a copy of such verification is mailed to the consumer by the debt collector.’’ 15  U.S.C. § 1692g(b).   31.  Plaintiff called Defendant on or around December 3, 2018, which was still within  the 30-day time period of receipt of the letter, to dispute the debt as per the rights outlined in  the collection letter he received.    32.  When asked the reason for his contacting the Defendant, Plaintiff informed the  representative with whom he spoke that he was disputing the validity of the debt, as per his  rights as printed on Defendant’s November 2, 2018 letter.   33.  Defendant’s representative refused to accept the Plaintiff’s dispute.    34.  Defendant’s representative informed Plaintiff that his dispute was invalid, and  demanded that Plaintiff must provide a specific reason for his dispute.   35.  Defendant’s dispute, made by telephone, meets the criteria set forth by § 1692g(a),  as it was made within thirty days of receipt of the notice, and he unequivocally stated that he  was disputing the validity of the debt.   36.  Furthermore, it well established in the 2nd Circuit that oral disputes are a  completely valid method of asserting a consumer’s rights under § 1692g.   37.  Advising the Plaintiff that his oral dispute of the debt was invalid unless he stated a  specific reason violates the consumers rights as provided for under the Fair Debt Collection  Practices Act.   38.  Defendant’s demand for reason for the dispute overshadowed Plaintiff’s §1692g  right to dispute the debt over the phone, or in general as no reason is required to be given by  the Plaintiff to validly exercise his dispute rights under 1692g(a).   39.  This false and deceptive tactic of demanding a specific reason before “accepting a  dispute as valid” is misleading because it confuses the consumer as to how to exert his dispute  and validation rights under FDCPA.    4. A statement that the consumer notifies the debt collector in writing  within thirty-day period that the debt, or any portion thereof, is disputed,  the debt collector will obtain verification of the debt or a copy of a  judgment against the consumer and a copy of such verification or  judgment will be mailed to the consumer by the debt collector; and   40.  Defendant intentionally chose to make it difficult for the Plaintiff to dispute the  debt, even though he did it in a proper manner.   41.  As a result of Defendant’s deceptive, misleading and false debt collection practices,  Plaintiff has been damaged.  42.  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.   43.  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.   44.   Pursuant to 15 USC §1692g, a debt collector:  (a) Within five days after the initial communication with a consumer in connection with  the collection of any debt, a debt collector shall, unless the following information is  contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing –   45.  The Defendant violated 15 U.S.C. §1692g:  a. By demanding a reason for Plaintiff’s dispute and rejecting the Plaintiff’s  dispute, despite the fact he validly exercised his dispute rights under the  5. A statement that, upon the consumer’s written request within the thirty- day period, the debt collector will provide the consumer with the name  and address of the original creditor, if different from the current  creditor.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692g  et seq.  