22.  On or around May of 2007, Plaintiff first purchased a Dell computer for personal  use and made subsequent personal purchases thereafter.     23.  In conjunction with Plaintiff’s order and each subsequent order, Dell Inc., agreed  to provide goods to Plaintiff and through that same transaction with Dell Inc., Plaintiff’s  purchase of goods was financed.     24.  This financing process is similar to those done by an automobile dealership,  where the dealership sells the good and arranges financing for the buyer.    25.  On information and belief, Dell placed the financing of Plaintiff’s purchase for  goods with Dell Financial Services LLC (“DFS”) and per DFS’ agreement with CIT Bank,  within two days from the date of the loan’s origination CIT transferred title of the loan back to  46.  Plaintiff incorporates paragraphs 1-45 above.  15 U.S.C § 1692e, in pertinent part, provides:  A debt collector may not use any false, deceptive, or misleading  representation or means in connection with the collection of any debt. Without  limiting the general application of the foregoing, the following conduct is a  violation of this section:  * * *  (2) The false representation of --  (A) the character, amount, or legal status of any debt. . . .  * * *  (5) The threat to take any action that cannot legally be taken or  that is not intended to be taken. . . .  * * *  (10) The use of any false representation or deceptive means to collect or  attempt to collect any debt or to obtain information concerning a consumer.   47.  The FDCPA broadly prohibits unfair or unconscionable collection methods  including filing suit on a time barred debt.  See e.g. Murray v. CCB Credit Services, Inc., 04 C  7456, 2004 U.S. Dist. LEXIS 25361, 2004 WL 2943656, at *2 (N.D. Ill. Dec. 15, 2004) ("[A]  violation of the FDCPA occurs if the attempt to collect the time-barred debt is accompanied by a  threat to sue, or if litigation has actually begun."); Walker v. Cash Flow Consultants, Inc., 200  F.R.D. 613, 616 (N.D. Ill. 2001);  Kimber v. Federal Financial Corp., 668 F. Supp. 1480 (M.D.  Ala. 1987).  Therefore, Plaintiff and the class members have a legal substantive right of not  being sued on a time barred debt.     49.  Defendants’ conduct for the purpose of the state law claim was willful.     50.  The subject debt and all debts like it that were incurred for purchases from Dell  where Dell arranged the financing, were subject to the Uniform Commercial Code, and therefore  subject to a 4-year statute of limitations.    51.  Defendants’ conduct related to the state court matter violated 15 U.S.C §§  1692e(2)(A), e(5) and e(10).   52.  In defending the state court matter, Plaintiff incurred out of pocket actual  damages.  53.  A complaint need not define the class rather, “the obligation to define the class  falls on the judge’s shoulders” who may ask the parties’ assistance.  Chapman v. First Index, Inc.,  796 F.3d 783, 785 (7th Cir. 2015) (citing Fed. R. Civ. P. 8(a); Fed. R. Civ. P. 23(c)(1); Kasalo v.  Harris & Harris, Ltd., 656 F.3d 557, 563 (7th Cir. 20011).   54.  On information and belief, the class is so numerous that joinder of all members is  impractical.  Plaintiff alleges on information and belief that there are more than 40 similarly  situated persons as Plaintiff who were sued on a time barred debt originating with the same  creditor.    55.  There are questions of law and fact common to the class that predominate over  any questions affecting only individual class members. The predominant common question is  whether Plaintiff and the class members were sued on a time barred debt.   57.  A class action is an appropriate method for the fair and efficient adjudication of  this controversy.   58.  Plaintiff incorporates paragraphs 1-45 above.   59.  15 U.S.C § 1692e, in pertinent part, provides:  A debt collector may not use any false, deceptive, or misleading  representation or means in connection with the collection of any debt. Without  limiting the general application of the foregoing, the following conduct is a  violation of this section:  * * *  (2) The false representation of --  (A) the character, amount, or legal status of any debt. . . .  * * *  (5) The threat to take any action that cannot legally be taken or  that is not intended to be taken. . . .  * * *  (10) The use of any false representation or deceptive means to collect or  attempt to collect any debt or to obtain information concerning a consumer.   60.  Defendants’ conduct likewise violated MCL 445.252(e) and MCL 445.252(f)(ii).   CLASS CLAIM   INDIVIDUAL CLAIM  