11.  Plaintiff brings 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 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.    15.  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.   16.  The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiff will fairly and adequately protect the interests of the  Plaintiff Class defined in this complaint. The Plaintiff has retained counsel with experience in  handling consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiff  nor his attorneys have any interests, which might cause them not to vigorously pursue this action.   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  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.   19.  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).  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 January 3, 2020, an obligation was allegedly incurred to Citibank,  N.A. by the Plaintiff.   22.  The Citibank, N.A. obligation arose out of transactions in which money, property,  insurance or services which are the subject of the transactions were primarily for personal,  family or household purposes, specifically a Citi Mastercard account.   23.  The alleged Citibank, N.A. obligation is a “debt” as defined by 15 U.S.C. §1692a(5).   24.  Citibank, N.A. is a “creditor” as defined by 15 U.S.C. §1692a(4).   25.  Defendant UCB, a debt collector, was contracted by Citibank, N.A. to collect the  alleged debt which originated with Citibank, N.A.   27.  On or about January 3, 2020, Defendant UCB sent Plaintiff a collection letter (the  “Letter”) regarding the alleged debt currently owed to Defendant Citibank, N.A. See Exhibit A.   28.  The collection letter provides the following description for the amount owed.  1) Account Balance: $12,197.02  2) Minimum Payment Due: $1882.02   29.  The collection letter states: “Because of interest and/or other charges that may vary  from day to day, the amount due on the day you pay may be greater.  Hence, if you pay the  amount shown above, an adjustment may be necessary after your payment is received.”   30.  The Defendant’s Letter fails to explain whether the potential “adjustment” is  applicable to a payment of the “Minimum Payment Due,” or the “Account Balance.”    31.  Plaintiff is without any guidance on where the purported amount written for each  category is sufficient or whether the adjustment will be applied to both the “Minimum Payment  Due,” and the “Account Balance,” or neither.   32.  Additionally, Defendant’s letter does not explain the term “other charges” and  Plaintiff has no way of determining what the “other charges” may be.   33.  Plaintiff has no basis to determine what “other charges” could affect his balance day  to day besides interest and late fees.   35.  If Defendant is aware of “other charges” that would lead to an increase in the balance,  Defendant should clarify and explain them in the letter.   36.  Plaintiff is unable to evaluate how much is owed, and what charges may actually be  included in an overall balance upon the time of payment.   37.  This statement from the Defendant is also a threat to collect an amount that is not  provided in the contract or by law.     38.  As a result of Defendant’s deceptive, misleading and false debt collection practices,  Plaintiff has been damaged.  39.  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.   40.  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. § 1692e.   41.  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.   42.  Defendant violated said section by:   a. Making a false and misleading representation in violation of but not limited to  §1692e (10).  b. by failing to delineate to which listed amount the “adjustment” may be applied.   44.  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.   45.  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.   46.  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.   47.  Defendant violated this section by   a. unfairly stating that the balance may increase due to “other charges”, when no  other charges are allowed by contract or law;   48.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692f, et seq. of the FDCPA and is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  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.  