17.      Plaintiff brings this case as a class action pursuant to Rules 23 of the  Federal Rules of Civil Procedure on behalf of herself and all others similarly  situated.   18.    Plaintiffs seek to represent a class defined as:  All consumers in the United States who were sent a  letter that is identical to or is substantially the  same form as the Letter by or on behalf of  Defendant, which seeks to collect an alleged  consumer debt, within one year prior to the filing of  this action and which was not returned as  undeliverable.  D.       Numerosity   19.       The Letters are mass-mailed form letters that Defendant sends out  to thousands of consumers in nationwide. Therefore, the members of the class are  believed to be so numerous that joinder of all members is impractical.   20.       Upon information and belief, Defendant sent or caused to be sent  thousands of similar deceptive Letters to consumers.   21.       The exact numbers and identities of class members are unknown at  this time and can only be ascertained through discovery. Identification of the  class members is a matter capable of ministerial determination from Defendant’s  records.   37.       Each and every allegation contained in paragraphs 1 through 36 of  this Complaint is repeated, realleged and incorporated herein by reference.   A.  The Account   The Class   VIOLATIONS OF FDCPA SECTION 15 U.S.C. § 1692G(B)     