(Violations of the Dodd-Frank Act)  (Violations of the FDCPA)  10. This Class satisfies all the requirements of FRCP Rule 23 for maintaining a class action. 11 .  The Class is so numerous that joinder of all members is impracticable. Upon information and belief, hundreds of persons have received debt collection notices and/or letters/communications from Defendants, which violate various provisions of the FDCPA.  12. The debt collection notices and/or letters/communications from Defendant, received by the Class, are to be evaluated by the objective standard of the hypothetical "least sophisticated consumer".  13. There are questions of law and fact which are common to the Class and which predominate over questions affecting any individual Class member. These common questions of law and fact include, without limitation: (i) Whether Defendantviolated various provisions of the FDCPA; (ii) Whether Plaintiff and the Class have been injured by Defendant's conduct; (c) Whether Plaintiff and the Class have sustained damages and are entitled to restitution as a result of Defendants' wrongdoing and, if so, what is the proper measure and appropriate statutoryformula to be applied in determining such damages and restitution; and, (iv) Whether Plaintiff and the Class are entitled to declaratory and/or injunctive relief.  15. A class action is superior to other methods for the fair and efficient adjudication of the claims herein asserted, this being specifically envisioned by Congress as a principal means of enforcing the FDCPA, as codified by 15 U.S.C. S 1692(k).  16. The members of the Class are generally unsophisticated individuals, whose rights will not be vindicated in the absence of a class action.  17. Prosecution of separate actions by individual members of the Class would create the risk of inconsistent or varying adjudications resulting in the establishment of inconsistent or varying standards for the parties.  18. A class action will permit a large number of similarly situated persons to prosecute their common claims in a single forum simultaneously, efficiently, and without the duplication of effort and expense that numerous individual actions would engender. Class treatment also will permit the adjudication of relatively small claims by many Class members who could not othenarise afford to seek legal redress for the wrongs complained of herein.  19. Plaintiff will fairly and adequately represent the Class members' interests, in that the Plaintiffs counsel is experienced and, further, anticipates no impediments in the pursuit and maintenance of the class action as sought herein.  20. Absent a class action, the Class members will continue to suffer losses borne from Defendant's breaches of their statutorily protected rights as well as monetary damages, thus allowing and enabling: (a) Defendants' conduct to proceed and; (b) Defendant to further enjoy the benefit of its ill-gotten gains.  22. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs numbered "1 " throu 9h"21" herein with the same force and effect as if the same were set forth at length herein.  23. Upon information and belief, Defendants began collecting an alleged consumer debt from the Plaintiff.  24. Upon information and belief, and better known to the Defendants, Defendant SYNCHRONY began their collection efforts and campaign of communications with the Plaintiff by mailing the Plaintiff a letter.  25. Defendant SYNCHRONY's letter dated September 8,2014 is attached hereto as Exhibit "A".  26. Defendant SYNCHRONY's letter featured an oversize heading in bold uppercase letters centered on the page.  27. The heading of stated: "CALL Genpact Services LLC IMMEDIATELY 1-877-828-1903 This is an urgent notice regarding your delinquent account. Call the number above as soon as possible to discuss your payment options. Failure to respond promptly could result in further steps being taken to collect the debt."  27. The body of Defendant's letter stated: "Calling now may be in your best interest and may help prevent additional damage to your credit report."  29. Defendant's January Letter featured a postscript as follows: "P.S. Further delay may only make matters worse. Call 1 -877-828-1903 to work out a payment plan. Don't wait. Call now."  30. At the very bottom of Defendant's letter was a legend formatted as a footnote [positioned flush beneath a one-inch line per footnote placement] in miniscule 6 or 7pt. font which provided a Mini-Miranda disclosure which did not identify either Defendant as a debt collector but only stated that the letter was an attempt to collect a debt and information obtained would be used for that purpose.  31. No 30-day verification disclosures were included in Defendant SYNCHRONY's initial letter to Plaintiff dated September 8,2014. 32. Ptaintiff repeats, reiterates and incorporates the allegations contained in paragraphs numbered "1" through "31" herein with the same force and effect as if the same were set forth at length herein.  34. 15 USC 51692 e - preface and e (10) prohibits a debt collector from using any false, deceptive or misleading representation or means in connection with the collection of any debt or to obtain information concerning a consumer.  39. 15 USC S1692e(11) requires that a debt collector provide the information that they are debt collectors attempting to collect a debt and that any information obtained will be used for that purpose in every communication made with a consumer.  40. The Defendants violated 15 USC $1692e (1 1) by deliberately and purposely printing said disclosures in a typeface so small as to be unreadable and positioning them so as to be overlooked by the least sophisticated consumer, with the intention of preventing their notice. 41 . 15 USC S1692 f - preface prohibits a debt collector from using any unfair or unconscionable actions in connection with the collection of a debt.  43. Pursuant to 15 USC S1692 g (a) (3), (4) and (5), in an initial communication with a consumer, or within five days after making initial contact, a debt collector is required to send written notice informing the consumer that: (3) the subject debt will be considered valid unless they are contacted by the consumer within 30 days stating othenruise; (a) if the consumer writes to the debt collector within 30 days to dispute the alleged debt, the debt collector will obtain verification or copy of judgment against the consumer and mail same to the consumer; and, (5) at the consumer's written request within the 30-day period, the debt collector will provide the name and address of the original creditor.  44. As agent for Defendant GENPACT, SYNCHRONY has failed to provide the required disclosures under the statute, denying consumers information to which they are entitled. lf Defendants' letter originated from Defendant GENPACT, a debt collector, GENPACT, by pretending to write from Defendant SYNCHRONY, is thus avoiding the proper and required disclosures in or following initial communication, in violation of 15 USC 51692 g (a) (3), (a) and (5).  46. As a result of Defendant's violations of the FDCPA, Plaintiff has been damaged and is entitled to damages in accordance with the FDCPA. 47. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs numbered "l " through "46" herein with the same force and effect as if the same were set forth at length herein.  48. According to the Consumer Financial Protection Bureau Bulletin 2013- 07, "Under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd- Frank Act), all covered persons or service providers are legally required to refrain from committing unfair, deceptive, or abusive acts or practices (collectively, UDAAPs) in violation of the Act." The CFPB Bulletin 2013-07, Section "C" defines unfair and abusive practices to include the misrepresentation about whether information about a payment or non-payment would be furnished to a credit reporting agency.  50. As a result of Defendant's violations of the FDCPA and the Dodd-Frank Act, Plaintiff has been damaged and is entitled to damages in accordance with the FDCPA.