11.  The OBLIGATION arose out of a transaction, in which money, property, insurance  or services, which are the subject of the transaction, are primarily for personal, family or household  purposes.   12.  Plaintiff incurred the OBLIGATION by obtaining goods and services which were  primarily for personal, family and household purposes.   13.  Plaintiff did not incur the OBLIGATION for business purposes.   14.  The OBLIGATION is a "debt" as defined by 15 U.S.C. § 1692a(5).   15.  At some time prior to August 5, 2020, the OBLIGATION was placed with  NATIONAL CREDIT SYSTEMS for the purpose of collection.    16.  At the time the OBLIGATION was placed with NATIONAL CREDIT SYSTEMS  for the purpose of collection, the balance was past due.   17.  At the time the OBLIGATION was placed with NATIONAL CREDIT SYSTEMS  for the purpose of collection, the obligation was in default.   18.  Plaintiff caused to be delivered to Defendant a letter dated August 5, 2020, which  were addressed to Defendant.  SEE Exhibit A, which is fully incorporated herein by reference.   19.  The August 5, 2020 letter was sent to Defendant in connection with the collection  of the OBLIGATION.   21.  After the date of the dispute, Defendant knew or should have known that the credit  information concerning the OBLIGATION would be communicated to creditors and other  persons.   22.  The credit information communicated to these creditors and other persons did not  indicate that the OBLIGATION was disputed.   23.  The credit information communicated to these creditors and other persons  concerning the OBLIGATION was false.   24.  Defendant failed to communicate to any person that the OBLIGATION is disputed.   25.  Since August 5, 2020, Defendant has communicated to at least one person, credit  information which is known or should be known to be false.   26.  NATIONAL CREDIT SYSTEMS knew or should have known that its actions  violated the FDCPA.   27.  Defendants could have taken the steps necessary to bring their actions within  compliance with the FDCPA, but neglected to do so and failed to adequately review its actions to  ensure compliance with the law.  30.  Plaintiff brings this action as a state-wide class action, pursuant to Rule 23 of the  Federal Rules of Civil Procedure (hereinafter “FRCP”), on behalf of himself and all Pennsylvania  consumers and their successors in interest (the “Class”), who were harmed by the Defendant’s  conduct in violation of the FDCPA, as described in this Complaint.   31.  This Action is properly maintained as a class action. The Class is initially defined  as:  All Pennsylvania consumers for whom Defendant communicated to any person  credit information which is known to be false and/or for whom Defendant failed  to communicate to any person that a disputed debt was disputed as set forth  herein.  The class definition may be subsequently modified or refined.  The Class period begins one year  to the filing of this Action.   33.  Plaintiff, on behalf of himself and others similarly situated, repeats and realleges all  prior allegations as if set forth at length herein.   34.  Defendant violated 15 U.S.C. § 1692e of the FDCPA by using any false,  deceptive or misleading representation or means in connection with its attempts to collect debts  from Plaintiff and others similarly situated.   35.  Defendant violated 15 U.S.C. § 1692e of the FDCPA in connection with  Plaintiff and others similarly situated.   37.  Defendant violated 15 U.S.C. § 1692e(2)(A) of the FDCPA by falsely  representing the character or legal status of the debt.   38.  By failing to communicate that a disputed debt was disputed, Defendant made  a false representation of the character or legal status of the debt.   39.  By communicating credit information which is known to be false or should be  known to be false, Defendant made a false representation of the character or legal status of the  debt.   40.  Section 1692e(8) of the FDCPA prohibits a debt collector from communicating  to any person credit information which is known to be false or should be known to be false,  including the failure to communicate that a disputed debt is disputed.    41.  Defendant violated 15 U.S.C. § 1692e(8) of the FDCPA by communicating to  any person credit information which is known to be false or should be known to be false.   42.  Defendant violated 15 U.S.C. § 1692e(8) of the FDCPA by failing to  communicate to any person that the OBLIGATION was disputed.   43.  Defendant violated 15 U.S.C. § 1692e(8) of the FDCPA by failing to  communicate to one or more of the credit reporting bureaus that the OBLIGATION was disputed.   44.  Section 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.   45.  By failing to communicate that the OBLIGATION was disputed as described  herein, Defendant engaged in a false representation or deceptive means to collect or attempt to  collect the debt.   47.  Plaintiff and others similarly situated have a right to free from abusive debt  collection practices by debt collectors.   48.  Plaintiff and others similarly situated have a right to have the Defendant abide  by its obligations under the FDCPA and those specifically found at 15 U.S.C. § 1692e(8).    49.  Plaintiff and others similarly situated have suffered harm as a direct result of  the abusive, deceptive and unfair collection practices described herein.   50.  Plaintiff has suffered damages and other harm as a direct result of the  Defendants’ actions, conduct, omissions and violations of the FDCPA described herein.   51.  Defendant’s failure to act as described herein caused harm to the credit of  Plaintiff and others similarly situated.   9.  Plaintiff is, at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. § 1692a(3).   FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §   1692 et seq.  VIOLATIONS  