11. Plaintiffs bring this claim on behalf of the following case, pursuant to  Fed. R. Civ. P. 23(a) and 23(b)(3).   13. 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.   14. Excluded from the Plaintiff Classes 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.    15. There are questions of law and fact common to the Plaintiff Classes,  which common issues predominate over any issues involving only individual  class members. The principal issue is whether the Defendants' written  communication to consumers, in the form attached as Exhibits A, violate 15  U.S.C. §§ l692e.   18. 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 Classes 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.   20. 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.   21. Some time prior to August 25, 2020, an obligation was allegedly  incurred to Capital One Bank (USA) N.A.   22. The Capital One Bank (USA) N.A. obligation arose out of transactions  in which money, property, insurance or services, which are the subject of the  transaction, are primarily for personal, family or household purposes.   23. Specifically, the Capital One Bank (USA) N.A. debt, was a credit card  used for personal, family and household purchases.   24. The alleged Capital One Bank (USA) N.A. obligation is a "debt" as  defined by 15 U.S.C.§ 1692a(5).   25. Capital One Bank (USA) N.A. is a "creditor" as defined by 15 U.S.C.§  1692a(4).   26. Defendant PRA, a debt collector and the subsequent owner of the  Capital One Bank (USA) N.A. debt, is collecting the alleged debt.   28. On or about August 25, 2020, Defendant PRA sent the Plaintiff a debt  collection letter (the “Letter”) regarding the alleged debt owed to Capital One  Bank (USA) N.A. See Exhibit A.   29. The Letter states a balance of $ 4,820.96.   30. The Letter offers two options regarding the balance: Either pay the full  amount or select a “savings plan” that allows the consumer to pay the balance  for a discounted amount.   31. Below the offer to pay in full, the letter states: “Your Account will be  considered paid-in-full after your final payment is successfully posted.”   32. Below the offer to pay the discounted amount, the letter states: “The  savings will be applied to the balance and your account will be considered  paid-in-full for less than the full balance after your final payment is  successfully posted.”   33. Below both offers, the Letter includes a sentence that states: “Within  approximately 30 days of your final payment successfully posting, we will  request that the three major credit reporting agencies delete our tradeline  related to your account from your credit bureau report.”   35. Upon Defendant’s request to delete the tradeline from the credit  bureaus upon final payment, the account will no longer appear on the credit  report of the Plaintiff in any form.   36. Therefore, there is no consequence to Defendant’s earlier statements in  the Letter that the account will be “considered” paid in full or “paid in full for  less than the full balance,” because in either scenario, the account will simply  not appear on Plaintiff’s credit report.   37. The earlier statements are deceptive and misleading, because they  propose to offer a benefit of considering the account “paid-in-full,” which  essentially does not exist, because the account will be deleted entirely upon  final payment.   38. Just the fact that letter at all states that there is a status for each type of  payment option is misleading, when in fact either option results in a complete  wiping away of the account having existed at all.   40. Plaintiff incurred an informational injury because the Defendants  falsely describe the effects of full payment as opposed to less than full  payment.   41. As a result of Defendants deceptive, misleading and unfair debt  collection practices, Plaintiff has been damaged.  42. 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.   43. 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.   44. 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.   46. By reason thereof, Defendants are liable to Plaintiff for judgment that  Defendants conduct violated Section 1692e et seq. of the FDCPA, actual  damages, statutory damages, costs and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15  U.S.C. §1692e et seq.  