1.  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.   13.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   15.  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.   16.  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.    17.  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. §§ l692e & 1692f.   2.  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. § 1692f.   20.  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.   21.  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).  22.  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.   24.  The Sprint Nextel obligation arose out of a transaction in which involved the  transaction of money, property, insurance or services primarily for personal, family or  household purposes.    25.  The alleged Sprint Nextel  obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   26.  Sprint Nextel  is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   27.  Defendant LVNV, a debt collector and subsequent owner of the Sprint Nextel debt,  contracted with Defendant TrueAccord to collect the alleged debt.   28.  Defendants collects and attempt to collect debts incurred or alleged to have been  incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and internet.  Violation – February 10, 2021 Collection Letter   29.  On or about February 17, 2021, Defendant TrueAccord sent Plaintiff a collection  letter (the “Letter”) regarding the alleged debt owed. A true and accurate copy of the Letter is  attached as Exhibit A.   3.  Pursuant to 15 U.S.C. §1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.   30.  The letter states a balance of $770.75.   31.  The letter states:  “We are TrueAccord, a third party debt collection agency.  We  are working on behalf of LVNV Funding LLC (current creditor of your original Sprint Nextel  Corporation account) to collect on your balance of $770.75.   33.  Upon information and belief, the statute of limitations to file a lawsuit on this debt  has long passed.   34.   The letter fails to clearly and adequately inform the consumer as to the true legal  status of the debt and potential ramifications of making a payment with a written  acknowledgement of the debt and thereby restarting the statute of limitations.   35.  Therefore, the letter puts the Plaintiff at material risk of making a partial payment  and thereby unknowingly recommencing the lapsed statute of limitations.   36.  Plaintiff sustained an informational injury in that he was deceptively misled about  the true legal nature of the alleged debt and was not advised that making payment on the debt  would restart the statute of limitations.   37.  As a result of Defendants’ deceptive, misleading and unfair debt collection  practices, Plaintiff has been damaged.  38.  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.   39.  Defendants 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.   4.  Defendant violated this section by omitting material information that gave Plaintiff  a false understanding of the rights provided him under the FDCPA.   40.  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.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692f  et seq.  