11. Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   13. 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.   14. 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.    15. 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 Defendants' written communications to consumers, in the forms  attached as Exhibit A, violate 15 U.S.C. §§ 1692e.   18. 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.   19. 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).  20. 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.   21. Some time prior to June 11, 2020, an obligation was allegedly incurred to creditor  Anesthesiology of Greenwood.   23. The alleged Anesthesiology of Greenwood obligation is a "debt" as defined by 15  U.S.C.§ 1692a(5).   24. Anesthesiology of Greenwood is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   25. Defendant ICS contracted with Anesthesiology of Greenwood to collect the alleged  debt.  Violation – June 11, 2020 Collection Letter   26. On or about June 11, 2020, Defendant ICS sent the Plaintiff an initial collection  letter (the “Letter”) regarding the alleged debt owed. See a true and correct copy of the  Letter attached at Exhibit A.   27. The letter states:   “Anesthesiology of Greenwood has provided the attached information, verifying  your responsibility for payment of the debt referenced in the Account Summary.  If you  still question that obligation, contact our office, otherwise your remittance of $3,992.55 is  required.  Anesthesiology of Greenwood is both the original and current creditor to whom  this debt is owed.    We forward information about the debts we handle to the national credit reporting  agencies in your creditor’s name.  Your dispute regarding the claimed amount will also be  reported.  You have the right to inspect your credit rating in accordance with federal law.”   28. The letter states that the account information is scheduled to be reported in “your  creditor’s name,” which according to the Letter is Anesthesiology of Greenwood.   30. In the alternative, if both Defendant ICS and the original creditor are both reporting  to the national reporting agencies, it would constitute deceptive double-reporting.    31. It is deceptive for two companies will report to the credit reporting agencies on the  same debt.   32. As a result of Defendant's deceptive, misleading and unfair 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 § 1692e:   a. As the Letter it is open to more than one reasonable interpretation, at least one  of which is inaccurate.  b. By making a false and misleading representation in violation of §1692e(10).   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e et  seq.  