14. Plaintiff brings claims, pursuant to the Federal Rules of Civil Procedure (hereinafter  “FRCP”) Rule 23, individually and on behalf of the following consumer class (the “Class”)    consisting of: a) All consumers who have an address in the state of Texas b) who were sent  an initial collection letter from the Defendant c) attempting to collect a consumer debt d)  which does not clearly identify the creditor to whom the debt is allegedly owed (e) which  letter was sent on or after a date one year prior to the filing of this action and on or before  a date 21 days after the filing of this action.   16. 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.   17. 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 Exhibit A, violate 15 U.S.C. § 1692e and 1692g.   18. The Plaintiffs’ claims are typical of the class members, as all are based upon the same  facts and legal theories.   19. 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.   22. 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).  23. 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.   24. Some time prior to August 12, 2016, Plaintiff incurred an obligation that arose out of a  transaction for personal, family or household purposes.   25. The alleged obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   26. Defendant contends that the debt is past due.   27. Defendant is a company that uses mail, telephone or facsimile in a business the principal  purpose of which is the collection of debts, or that regularly collects or attempts to collect  debts incurred or alleged to have been incurred for personal, family or household purposes  on behalf of creditors.   28. The creditor of this obligation directly or through an intermediary contracted the Defendant  to collect the alleged debt.   29. On or about August 12, 2016, the Defendant caused to be delivered to the Plaintiff a  collection letter in an attempt to collect the alleged debt. See Exhibit A.   30. Upon information and belief, the August 12, 2016 letter was the first communication  between the Defendant and Plaintiff regarding the alleged debt.   32. The August 12, 2016 letter is a “communication” as defined by 15 U.S.C. §1692a(2).   33. The Plaintiff received and read the Letter sometime after August 12, 2016.   34. The Letter stated in part:  Total Balance Due:  $1,869.55”   35. The Letter further stated:   36. By listing a different creditor and current creditor, the plaintiff was left unsure as to which  creditor the Defendant was seeking to collect for.   37. Pursuant to 15 U.S.C. §1692g(a)(2) a debt collector must within five days after the initial  communication, send the consumer a written notice containing the name of the creditor to  whom the debt is owed.   38. The obligation is not only to identify the name of the creditor, but to convey the name of  the creditor clearly and explicitly.   40. “Thus, in order to comply with the requirements of section 1692g, more is required than  the mere inclusion of the statutory debt validation notice in the debt collection letter, the  required notice must also be conveyed effectively to the debtor.” See, Graziano v.  Harrison, 950 F.2d 107, 111 (3d Cir .1991). Moreover, the validation notice required by  the Act “is to be interpreted from the perspective of the ‘least sophisticated debtor.’ ”  Graziano, 950 F.2d at 111   41. Congress further desired to “eliminate the recurring problem of debt collectors dunning the  wrong person or attempting to collect debts which the consumer has already paid.”  S.Rep.  No. 95–382, at 4 (1977), reprinted in 1977 U.S.C.C.A.N. 1695, 1699.   42. The rights afforded to consumers under Section 1692g are amongst the most powerful  protections provided by the FDCPA.  A consumer who receives notice of the rights  provided by that section, and who exercises his right to dispute the debt, has the power to  stop collection activity until verification of the debt is provided.   43. By failing to identify the current creditor to whom the debt is owed, the Defendant caused  the Plaintiff real harm, by depriving her of information which she had a statutorily granted  right to receive.  44. 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.   46. The Defendant violated said provision by using false representation or deceptive means to  collect or attempt to collect a debt in violation of 1692e(10).   47. The Defendant further violated said provision by failing to clearly convey the name of the  current creditor in violation of 1692g(a)(2).   48. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's conduct  violated Section 1692 et seq. of the FDCPA, actual damages, statutory damages, costs and  attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692 et seq.  