  (Violations of the FDCPA)   11.   The debt collection notices and/or letters/communications from Defendant,  received by the Class, are to be evaluated by the objective standard of the hypothetical  “least sophisticated consumer.”   12.  There are questions of law and fact which are common to the Class and  which predominate over questions affecting any individual Class member. These common  questions of law and fact include, without limitation: (i) Whether Defendant violated various  provisions of the FDCPA; (ii) Whether Plaintiff and the Class have been injured by  Defendant’s conduct; (c) Whether Plaintiff and the Class have sustained damages and are  entitled to restitution as a result of Defendant’s wrongdoing and, if so, what is the proper  measure and appropriate statutory formula to be applied in determining such damages and  restitution; and, (iv) Whether Plaintiff and the Class are entitled to declaratory and/or  injunctive relief.   13.  Plaintiff’s claims are typical of the claims of the Class, and Plaintiff has no  interests adverse or antagonistic to the interests of other members of the Class.   14.  A class action is superior to other methods for the fair and efficient  adjudication of the claims herein asserted, this being specifically envisioned by Congress  as a principal means of enforcing the FDCPA, as codified by 15 U.S.C. § 1692(k).     15.  The members of the Class are generally unsophisticated individuals, whose  rights will not be vindicated in the absence of a class action.     17.   A class action will permit a large number of similarly situated persons to  prosecute their common claims in a single forum simultaneously, efficiently, and without  the duplication of effort and expense that numerous individual actions would engender.  Class treatment also will permit the adjudication of relatively small claims by many Class  members who could not otherwise afford to seek legal redress for the wrongs complained  of herein.   18.   Plaintiff will fairly and adequately represent the Class members’ interests, in  that the Plaintiff’s counsel is experienced and, further, anticipates no impediments in the  pursuit and maintenance of the class action as sought herein.   19.  Absent a class action, the Class members will continue to suffer losses borne  from Defendant’s breaches of Class members' statutorily protected rights as well as  monetary damages, thus allowing and enabling:  (a) Defendant’s conduct to proceed and;  (b) Defendant to further enjoy the benefit of its ill-gotten gains.   20.   Defendant has acted, and will act, on grounds generally applicable to the  entire Class, thereby making appropriate a final injunctive relief or corresponding  declaratory relief with respect to the Class as a whole.  21.  Plaintiff repeats, reiterates and incorporates the allegations contained in  paragraphs numbered “1” through “20” herein with the same force and effect as if the same  were set forth at length herein.    22.  Upon information and belief, Defendant, on behalf of a third-party, began  efforts to collect an alleged consumer debt from the Plaintiff.    24.  Defendant’s aforementioned letter bore a “Re” of: “Ng Guide To Brain  Health Dix.”   25.  Defendant’s aforementioned letter contained the following language:  “Apparently someone has led you to believe that creditors like National  Geographic Society will eventually forget about the money you owe them. Please let  us correct that mistaken idea. Our client has employed us to make sure you know this  account will not be forgotten. In fact, we have been specifically requested to pursue  additional collections.  Consider your position in this matter.  1) You requested and received merchandise or services from our client.  2) You were properly billed for this purchase.  3) Despite numerous requests, you have not paid this legitimate debt.  These are facts, and they leave no justification for your lack of response. So, it  only makes good sense to settle this matter at once by sending in your payment  along with the bottom portion of this letter.”  26.  Plaintiff repeats, reiterates and incorporates the allegations contained in  paragraphs numbered “1” through “25” herein with the same force and effect as if the same  were set forth at length herein.   29.  15 USC §1692 e – preface prohibits a debt collector from using any false,  deceptive or misleading representation or means in the connection with the collection of  any debt.   31.  15 USC §1692 e (7) prohibits a debt collector from any false  representation or implication that the consumer is guilty of disreputable conduct in order  to disgrace the consumer while attempting to collect a debt.   32.  Defendant violated 15 USC §1692 e (7) by indicating that Plaintiff has  “apparently” been “led to believe” that creditors will forget debts and it is Defendant’s  express job to disabuse them of this fantasy and “make sure you know this account will  not be forgotten,” followed by a claim that the “facts” indicate that the consumer has  refused to pay a “legitimate” debt and has “no justification” for not paying. Defendant’s  language is deliberately and purposefully designed to embarrass, disgrace and shame  consumers and to disparage the consumer’s character by stating that it has been  unequivocally determined, without a doubt, that the consumer has behaved in a  disgraceful, disrespectable and dishonorable manner and essentially, is guilty of what  amounts to attempting to steal merchandise.    33.  15 USC §1692 f – preface prohibits a debt collector from using any unfair  or unconscionable means in connection with the collection of a debt.   8.  Plaintiff brings this action as a class action, pursuant to Federal Rules of Civil  Procedure (“FRCP”) Rule 23, on behalf of herself and all persons/consumers, along with  their successors-in-interest, who have received similar debt collection notices and/or  letters/communications from Defendant which, as alleged herein, are in violation of the  FDCPA, as of the date of Plaintiff’s Complaint (the “Class”).  Excluded from the Class is  Defendant herein, and any person, firm, trust, corporation, or other entity related to or  affiliated with the defendant, including, without limitation, persons who are officers,  directors, employees, associates or partners of Defendant. Upon information and belief,  hundreds of persons have received debt collection notices and/or letters/communications  from Defendant, which violate various provisions of the FDCPA.    9.  This Class satisfies all the requirements of FRCP Rule 23 for maintaining a  class action.  