19.  On or about December 24, 2015, Defendant sent a written communication to  Plaintiff in connection with the collection of the Debt.  A true and correct copy of the relevant  page of the December 24, 2015 communication is attached hereto as Exhibit A.   20.  The December 24, 2015 communication was the first communication Plaintiff  received from Defendant concerning the Debt.   21.  Plaintiff did not receive any additional communications from Defendant within  five days of the December 24, 2015 communication.   22.  The December 24, 2015 communication to Plaintiff stated, “Your Sam’s Club  MasterCard Account, which was issued by and owed to Synchrony Bank, has been referred to us  by our client for collection.”  See Ex. A.   25.  Further, Defendant’s December 24, 2015 communications also violated 15 U.S.C.  § 1692g(a)(5) by failing to inform Plaintiff that Defendant need only provide him the name and  address of the original creditor, if different from the current creditor, if he notified Defendant of  such request, in writing.    27.  Defendant’s misstatement of the rights afforded by the FDCPA would cause the  least-sophisticated consumer to understand, incorrectly, that validation of the debt, or a request  for the name and address of the original creditor, could be obtained through an oral request, or by  means other than in writing.  Such a misunderstanding could lead the least-sophisticated  consumer to waive or otherwise not properly vindicate her rights under the FDCPA.    28.  Indeed, failing to dispute the debt in writing, or failing to request the name and  address of the original creditor, in writing, would cause a consumer to waive the important  protections afforded by 15 U.S.C. § 1692g(b)—namely, that a debt collector cease contacting the  consumer until the debt collector provides the consumer with verification of the alleged debt  and/or the original creditor’s name and address, as requested.   30.  Plaintiff bring this action as a class action pursuant to Federal Rules of Civil  Procedure 23(a) and (b)(3) on behalf of a class consisting of:  (a) All persons with a Florida address, (b) to whom GC Services Limited  Partnership mailed an initial debt collection communication that stated: (1) “if  you do dispute all or any portion of this debt within 30 days of receiving this  letter, we will obtain verification of the debt from our client and send it to  you,” and/or (2) “if within 30 days of receiving this letter you request the  name and address of the original creditor, we will provide it to you in the  event it differs from our client,” (c) in the one year preceding the date of this  complaint, (d) in connection with the collection of a consumer debt.   Excluded from the class is Defendant, its officers and directors, members of their immediate  families and their legal representatives, heirs, successors, or assigns, and any entity in which  Defendant has or had controlling interests.   31.  The proposed class satisfies Fed. R. Civ. P. 23(a)(1) because, upon information  and belief, it is so numerous that joinder of all members is impracticable.  The exact number of  class members is unknown to Plaintiff at this time and can only be ascertained through  appropriate discovery.  The proposed class is ascertainable in that, upon information and belief,  the names and addresses of all members of the proposed class can be identified in business  records maintained by Defendant.     32.  The proposed class satisfies Fed. R. Civ. P. 23(a)(2) and (3) because Plaintiff’s  claims are typical of the claims of the members of the class.  To be sure, the claims of Plaintiff  and all of the members of the class originate from the same conduct, practice and procedure on  the part of Defendant, and Plaintiff possesses the same interests and has suffered the same  injuries as each member of the proposed class.   34.  A class action is superior to all other available methods for the fair and efficient  adjudication of this controversy, since joinder of all members is impracticable.     35.  Furthermore, as the damages suffered by individual members of the class may be  relatively small, the expense and burden of individual litigation make it impracticable for the  members of the class to individually redress the wrongs done to them.  There will be no  difficulty in the management of this action as a class action.   36.  Issues of law and fact common to the members of the class predominate over any  questions that may affect only individual members, in that Defendant has acted on grounds  generally applicable to the class.  Among the issues of law and fact common to the class are:  a. Defendant’s violations of the FDCPA as alleged herein;  b. Defendant’s failure to properly provide in its initial debt collection letter the  disclosures required by 15 U.S.C. § 1692g;  c. Whether Defendant is a debt collector as defined by the FDCPA;  d. the existence of Defendant’s identical conduct particular to the matters at issue;  e. the availability of statutory penalties; and  f. the availability of attorneys’ fees and costs.  37.  Plaintiff repeats and re-alleges each and every allegation contained in paragraphs  1 through 36.   39.  Defendant’s December 24, 2015 communication did not contain the proper  disclosures required by 15 U.S.C. § 1692g(a)(4), and Defendant did not provide such disclosures  within five days thereafter.   40.  Specifically, the December 24, 2015 communication violated 15 U.S.C. §  1692g(a)(4) by failing to inform Plaintiff that Defendant need only mail verification of the Debt  to him, and a copy of any judgment, if he notified Defendant that he disputed the Debt, or any  portion thereof, in writing.   41.  As a result, Defendant violated 15 U.S.C. § 1692g(a)(4).  42.  Plaintiff repeats and re-alleges each and every allegation contained in paragraphs  1 through 36.   44.  Defendant’s December 24, 2015 communication did not contain the proper  disclosures required by 15 U.S.C. § 1692g(a)(5), and Defendant did not provide such disclosures  within five days thereafter.   45.  Specifically, the December 24, 2015 communication violated 15 U.S.C. §  1692g(a)(5) by failing to inform Plaintiff that Defendant need only provide him the name and  address of the original creditor, if different from the current creditor, if he notified Defendant of  his request for that information in writing.   46.  As a result, Defendant violated 15 U.S.C. § 1692g(a)(5).  47.  Plaintiff repeats and re-alleges each and every allegation contained in paragraphs  1 through 36.   48.  The FDCPA at 15 U.S.C. § 1692e provides, in pertinent part, that “[a] debt  collector may not use any false, deceptive, or misleading representation or means in connection  with the collection of any debt.”   49.  Defendant’s December 24, 2015 communication did not contain the proper  disclosures required by 15 U.S.C. § 1692g(a)(4) and 15 U.S.C. § 1692g(a)(5), and Defendant did  not provide such disclosures within five days thereafter.   PRACTICES ACT, 15 U.S.C. § 1692e   PRACTICES ACT, 15 U.S.C. § 1692g(a)(4)   PRACTICES ACT, 15 U.S.C. § 1692g(a)(5)  