117.  Plaintiff brings this action individually and as a class action on behalf of all  persons similarly situated in the State of New York.  118.  Plaintiff seeks to certify a class of:  All consumers to whom Defendant sent a collection letter  substantially and materially similar to the Letter sent to Plaintiff,  which letter was sent on or after a date one year prior to the filing of  this action to the present.  119.  This action seeks a finding that Defendant's conduct violates the FDCPA, and  asks that the Court award damages as authorized by 15 U.S.C. § 1692k.  120.  The Class consists of more than thirty-five persons.  121.  Plaintiff's claims are typical of the claims of the Class. Common questions of law  or fact raised by this action affect all members of the Class and predominate over any individual  12  issues.  Common relief is therefore sought on behalf of all members of the Class. A class action is  superior to other available methods for the fair and efficient adjudication of this controversy.  122.  The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of the  Class, and a risk that any adjudications with respect to individual members of the Class would, as  a practical matter, either be dispositive of the interests of other members of the Class not party to  the adjudication, or substantially impair or impede their ability to protect their interests.  Defendant has acted in a manner applicable to the Class as a whole such that declaratory relief is  warranted.  123.  Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class is not extraordinarily difficult, and the factual and legal issues  raised by this action will not require extended contact with the members of the Class, because  Defendant's conduct was perpetrated on all members of the Class and will be established by  common proof.  Moreover, Plaintiff has retained counsel experienced in actions brought under  consumer protection laws.  21.  Defendant alleges Plaintiff owes a debt (“the alleged Debt”).     22.  The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of  a transaction in which the money, property, insurance, or services which are the subject of the  transaction are primarily for personal, family, or household purposes.   23.  The alleged Debt does not arise from any business enterprise of Plaintiff.   24.  The alleged Debt is a “debt” as defined by 15 U.S.C. § 1692a(5).   25.  At an exact time known only to Defendant, the alleged Debt was assigned or  otherwise transferred to Defendant for collection.   4   26.  At the time the alleged Debt was assigned or otherwise transferred to Defendant  for collection, the alleged Debt was in default.   27.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff by letter  (“the Letter”) dated July 1, 2019. (A true and accurate copy is annexed hereto as “Exhibit 1.”)   28.  The Letter conveyed information regarding the alleged Debt.   29.  The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).    30.  The Letter was the initial written communication Plaintiff received from  Defendant concerning the alleged Debt.   31.  The Letter was received and read by Plaintiff.   32.  15 U.S.C. § 1692g protects Plaintiff's concrete interests. Plaintiff has the interest  and right to receive a clear, accurate and unambiguous validation notice, which allows a  consumer to confirm that he or she owes the debt sought to be collected by the debt collector. As  set forth herein, Defendant deprived Plaintiff of this right.   33.  15 U.S.C. § 1692e protects Plaintiff's concrete interests. Plaintiff has the interest  and right to be free from deceptive and/or misleading communications from Defendant. As set  forth herein, Defendant deprived Plaintiff of this right.   34.  The deprivation of Plaintiff's rights will be redressed by a favorable decision  herein.  35.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     36.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.   37.  As relevant here, 15 U.S.C. § 1692g(a)(1) requires the written notice provide “the  amount of the debt.”   38.  To comply with 15 U.S.C. § 1692g(a)(1), a statement of “the amount of the debt”  must accurately convey, from the perspective of the least sophisticated consumer, the actual  amount of the debt.   39.  A statement of “the amount of the debt,” when the debt is not owed at all by the  5  consumer, violates 15 U.S.C. § 1692g(a)(1).   40.  The Letter claims that Plaintiff owes $514.14.   41.  Plaintiff did not owe $514.14.   42.  Plaintiff did not owe any money at all to the entity on whose behalf Defendant  was seeking to collect.   43.  Defendant's statement of the amount of the alleged Debt, when Plaintiff did not  owe any money at all to the entity on whose behalf Defendant was seeking to collect, violates 15  U.S.C. § 1692g(a)(1).   44.  For the foregoing reasons, Defendant violated 15 U.S.C. § 1692g(a)(1) and is  liable to Plaintiff therefor.  45.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.   46.  15 U.S.C. § 1692e provides, generally, that a debt collector may not use any false,  deceptive, or misleading representation or means in connection with the collection of any debt.    47.  An allegation by a debt collector that a consumer owes a debt, when the debt is  not owed at all by the consumer, is a false representation made in connection with the collection  of any debt, in violation of 15 U.S.C. § 1692e.   48.  An allegation by a debt collector that a consumer owes a debt, when the debt is  not owed at all by the consumer, is a deceptive representation made in connection with the  collection of any debt, in violation of 15 U.S.C. § 1692e.   49.  An allegation by a debt collector that a consumer owes a debt, when the debt is  not owed at all by the consumer, is a misleading representation made in connection with the  collection of any debt, in violation of 15 U.S.C. § 1692e.   50.  15 U.S.C. § 1692e(2)(A) prohibits the false representation of the character,  amount, or legal status of any debt.   51.  An allegation by a debt collector that a consumer owes a debt, when the debt is  not owed at all by the consumer, is a false representation of the character of the debt, in violation  of 15 U.S.C. § 1692e(2)(A).  6   52.  An allegation by a debt collector that a consumer owes a debt, when the debt is  not owed at all by the consumer, is a false representation of the amount of the debt, in violation  of 15 U.S.C. § 1692e(2)(A).   53.  An allegation by a debt collector that a consumer owes a debt, when the debt is  not owed at all by the consumer, is a false representation of the legal status of the debt, in  violation of 15 U.S.C. § 1692e(2)(A).   54.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     55.  An allegation by a debt collector that a consumer owes a debt, when the debt is  not owed at all by the consumer, is a false representation made in an attempt to collect the debt in  violation of 15 U.S.C. § 1692e(10).   56.  An allegation by a debt collector that a consumer owes a debt, when the debt is  not owed at all by the consumer, is a deceptive means used in an attempt to collect the debt in  violation of 15 U.S.C. § 1692e(10).   57.  The Letter alleges that Plaintiff owed $514.14.   58.  Plaintiff did not owe $514.14.   59.  Plaintiff did not owe any money at all to the entity on whose behalf Defendant  was seeking to collect.   60.  Defendant's allegation that Plaintiff owed $514.14, when Plaintiff did not owe any  money at all to the entity on whose behalf Defendant was seeking to collect, is a false  representation made by Defendant in connection with Defendant's collection of the alleged Debt,  in violation of 15 U.S.C. § 1692e.   61.  Defendant's allegation that Plaintiff owed $514.14, when Plaintiff did not owe any  money at all to the entity on whose behalf Defendant was seeking to collect, is a deceptive  representation made by Defendant in connection with Defendant's collection of the alleged Debt,  in violation of 15 U.S.C. § 1692e.   62.  Defendant's allegation that Plaintiff owed $514.14, when Plaintiff did not owe any  money at all to the entity on whose behalf Defendant was seeking to collect, is a misleading  representation made by Defendant in connection with Defendant's collection of the alleged Debt,  in violation of 15 U.S.C. § 1692e.  7   63.  Defendant's allegation that Plaintiff owed $514.14, when Plaintiff did not owe any  money at all to the entity on whose behalf Defendant was seeking to collect, is a false  representation of the character of the alleged Debt, in violation of 15 U.S.C. § 1692e(2)(A).   64.  Defendant's allegation that Plaintiff owed $514.14, when Plaintiff did not owe any  money at all to the entity on whose behalf Defendant was seeking to collect, is a false  representation of the amount of the alleged Debt, in violation of 15 U.S.C. § 1692e(2)(A).   65.  Defendant's allegation that Plaintiff owed $514.14, when Plaintiff did not owe any  money at all to the entity on whose behalf Defendant was seeking to collect, is a false  representation of the legal status of the alleged Debt, in violation of 15 U.S.C. § 1692e(2)(A).   66.  Defendant's allegation that Plaintiff owed $514.14, when Plaintiff did not owe any  money at all to the entity on whose behalf Defendant was seeking to collect, is a false  representation made in an attempt to collect the alleged Debt in violation of 15 U.S.C. §  1692e(10).   67.  Defendant's allegation that Plaintiff owed $514.14, when Plaintiff did not owe any  money at all to the entity on whose behalf Defendant was seeking to collect, is a deceptive means  used in an attempt to collect the alleged Debt in violation of 15 U.S.C. § 1692e(10).   68.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692e, 1692e(2)(A)  and 1692e(10) and is liable to Plaintiff therefor.  69.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     70.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.   71.  As relevant here, 15 U.S.C. § 1692g(a)(2) requires the written notice provide “the  name of the creditor to whom the debt is owed.”   72.  To comply with 15 U.S.C. § 1692g(a)(2), the written notice must accurately state  “the name of the creditor to whom the debt is owed.”   73.  A statement of “the name of the creditor to whom the debt is owed,” when the  consumer does not any money at all to the stated entity, violates 15 U.S.C. § 1692g(a)(2).  8   74.  The Letter claims the name of the creditor to whom the alleged Debt is owed is  Bureaus Investment Group Portfolio No 15 LLC.   75.  Plaintiff did not owe the alleged Debt to Bureaus Investment Group Portfolio No  85.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.   86.  15 U.S.C. § 1692e provides, generally, that a debt collector may not use any false,  deceptive, or misleading representation or means in connection with the collection of any debt.    87.  An allegation by a debt collector that a consumer owes a debt to a certain entity,  when the debt is not owed by the consumer to that entity, is a false representation made in  connection with the collection of any debt, in violation of 15 U.S.C. § 1692e.  9   88.  An allegation by a debt collector that a consumer owes a debt to a certain entity,  when the debt is not owed by the consumer to that entity, is a deceptive representation made in  connection with the collection of any debt, in violation of 15 U.S.C. § 1692e.   89.  An allegation by a debt collector that a consumer owes a debt to a certain entity,  when the debt is not owed by the consumer to that entity, is a misleading representation made in  connection with the collection of any debt, in violation of 15 U.S.C. § 1692e.   90.  15 U.S.C. § 1692e(2)(A) prohibits the false representation of the character,  amount, or legal status of any debt.   91.  An allegation by a debt collector that a consumer owes a debt to a certain entity,  when the debt is not owed by the consumer to that entity, is a false representation of the  character of the debt, in violation of 15 U.S.C. § 1692e(2)(A).   92.  An allegation by a debt collector that a consumer owes a debt to a certain entity,  when the debt is not owed by the consumer to that entity, is a false representation of the amount  of the debt, in violation of 15 U.S.C. § 1692e(2)(A).   93.  An allegation by a debt collector that a consumer owes a debt to a certain entity,  when the debt is not owed by the consumer to that entity, is a false representation of the legal  status of the debt, in violation of 15 U.S.C. § 1692e(2)(A).   94.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     95.  An allegation by a debt collector that a consumer owes a debt to a certain entity,  when the debt is not owed by the consumer to that entity, is a false representation made in an  attempt to collect the debt in violation of 15 U.S.C. § 1692e(10).   96.  An allegation by a debt collector that a consumer owes a debt to a certain entity,  when the debt is not owed by the consumer to that entity, is a deceptive means used in an attempt  to collect the debt in violation of 15 U.S.C. § 1692e(10).   97.  The Letter claims that Plaintiff owes a debt to Bureaus Investment Group  Portfolio No 15 LLC.   98.  Plaintiff did not owe a debt to Bureaus Investment Group Portfolio No 15 LLC.    99.  Bureaus Investment Group Portfolio No 15 LLC never offered to extend credit to  Plaintiff.  100.  Bureaus Investment Group Portfolio No 15 LLC never extended credit to  10  Plaintiff.  101.  Plaintiff was never involved in any transaction with Bureaus Investment Group  Portfolio No 15 LLC.  102.  Plaintiff never entered into any contract with Bureaus Investment Group Portfolio  No 15 LLC.  103.  Plaintiff never did any business with Bureaus Investment Group Portfolio No 15  Violation of 15 U.S.C. § 1692g(a)(2)   Violation of 15 U.S.C. § 1692g(a)(1)   Violations of 15 U.S.C. §§ 1692e, 1692e(2)(A) and 1692e(10)   Violations of 15 U.S.C. §§ 1692e, 1692e(2)(A) and 1692e(10)  