1. states in substance:  Unless the consumer, within 30 days after receipt of the notice,  disputes the validity of the debt, or any portion thereof, the debt  will be assumed to be valid by the debt collector. If written dispute  is made within 30 days, then we will obtain verification of the debt  or copy of judgment which we will mail to you, and if so requested,  the name and address of the original creditor, if different from the  current creditor.  or;    11.  Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ. P.  23(a) and 23(b)(3).   12.  The Class consists of:   a. all individuals with addresses in the State of Colorado;  b. to whom Defendant Revenue sent an initial letter;  c. attempting to collect a consumer debt;  d. in two sub-classes where the letter   14.  Excluded from the Plaintiff Class are the defendant and all officers, members, partners,  managers, directors and employees of the defendant 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 Defendant’s written communication to consumers, in the form attached as Exhibit A, violate 15  U.S.C. §§ 1692e, 1692f and 1692g.   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.   2. states that the name of the current creditor is on the “next page” although  the name of the current creditor is not on the next page; and  e. which letter was sent on or after a date one year prior to the filing of this action and  on or before a date twenty-one (21) days after the filing of this action.   20.  Plaintiff repeats the above allegations as if set forth here.   21.  Some time prior to November 3, 2020, Plaintiff allegedly incurred an obligation to non- party Valley View Hospital.   22.  The obligation arose out of transactions incurred primarily for personal, family, or  household purposes, specifically medical services.   23.  The alleged Valley view Hospital obligation is a "debt" as defined by 15 U.S.C.§ 1692a  (5).   24.  Revenue is a "creditor" as defined by 15 U.S.C.§ 1692a (4).   25.  Upon information and belief, Valley View Hospital contracted with Defendant Revenue  to collect the alleged debt.   26.  Defendant Revenue collects and attempts to collect debts incurred or alleged to have  been incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and internet.  Violation - November 3, 2020 Collection Letter   27.  On or about November 3, 2020, Defendant Revenue sent Plaintiff a collection letter  regarding the alleged debt, originally owed to Valley View hospital.  See Letter attached as Exhibit  A.   28.  The Letter seemingly includes the notices required by 15 U.S.C. 1692g.   29.  However, the notices are not compliant with the statute.   31.  Defendant’s letter includes a misleading version of the Section 1692g notices.   32.  Defendant’s notice did not conform to Section 1692g.   33.  First, The Faulty Notice’s first sentence refers to a “debt collector”.   34.  Yet, the following sentence refers to “we”, instead.   35.  The contrasting terms renders the notice misleading and confusing.   36.  In light of the contrasting terms, Plaintiff is confused as to whom the “we” refers if not  Defendant, or alternatively to whom the term “debt collector” refers if not Defendant.   37.  In addition, the Faulty Notice states “if a written dispute is made within 30 days”  without a timeline for when the “30 days” begin.   38.  The statute requires the notice to state “within thirty days after receipt of the notice”.   39.  Plaintiff was unaware how much time she had to dispute the debt.   40.  The Letter could imply that Plaintiff had thirty days from when she sends in her dispute  or thirty days from the date of the letter.    41.  Both of these implications are incorrect.   42.  The statute only provides for thirty days “after receipt of the notice”.   43.  This part of the Faulty Notice improperly truncated Plaintiff’s time for disputing the  debt or falsely appeared to extend it.   44.  Upon information and belief, Defendant would not honor a dispute sent more than thirty  days after receipt of this letter by Plaintiff.   45.  More importantly, Defendant would be under no legal obligation to do so.   47.  15 U.S.C. § 1692g requires a debt collector, in its initial communication, to include:  (4) a statement that if the consumer notifies the debt collector in writing within the  thirty-day period that the debt, or any portion thereof, is disputed, the debt collector  will obtain verification of the debt or a copy of a judgment against the consumer and  a copy of such verification or judgment will be mailed to the consumer by the debt  collector; and   (5) a statement that, upon the consumer’s written request within the thirty-day period,  the debt collector will provide the consumer with the name and address of the original  creditor, if different from the current creditor.   48.  However, the Faulty Notice here does not state this.   49.  The Faulty notice includes the statement, “If written dispute is made within 30 days,  then we will obtain verification of the debt or copy of judgment which we will mail to you, and if  so requested, the name and address of the original creditor, if different from the current creditor.”   50.  The Faulty Notice merged the sub-section (4) and (5) notices into one sentence,  separated by a comma, and then inserted the words “and if so requested”.   51.  The first part of the sentence refers to a dispute but the second half refers to a request.    52.  Because no written requirement is mentioned in the second part of the sentence, it  appears as if Plaintiff could orally request the name and address of the original creditor.   53.  Upon information and belief, Defendant would not honor an oral request for this  information.   54.  More importantly, Defendant would be under no legal obligation to do so.   55.  The Letter is therefore false, misleading, and deceptive.   56.  Due to Defendant’s actions, Plaintiff was confused and thought verbal and written  disputes would present equal rights when, in fact, they did not.   61.  The letter misleadingly implies that Revenue Enterprises is the creditor for this alleged  debt.   62.  Upon information and belief, the creditor is, in reality, Valley View Hospital.   64.  Because of this obfuscation by Defendant, the Letter fails to clearly identify, or at least  overshadows, the correct “name of the creditor to whom the debt is owed”. 15 U.S.C. §1692g (2).    65.  Defendant’s actions were false, deceptive, and/or misleading.   66.  Plaintiff was concerned and confused by the Letter.    67.  Plaintiff was therefore unable to evaluate his options of how to handle this debt.   68.  Because of this, Plaintiff expended time, money, and effort in determining the proper  course of action.   69.  In addition, Plaintiff suffered emotional harm due to Defendant’s improper acts.   70.  These violations by Defendant were knowing, willful, negligent and/or intentional, and  Defendant did not maintain procedures reasonably adapted to avoid any such violations.   72.  Defendant’s deceptive, misleading and unfair representations with respect to its  collection efforts were material misrepresentations that affected and frustrated Plaintiff's ability to  intelligently respond to Defendant’s collection efforts because Plaintiff could not adequately  respond to Defendant’s demand for payment of this debt.   73.  Defendant’s actions created an appreciable risk to Plaintiff of being unable to properly  respond or handle Defendant’s debt collection.   74.  Plaintiff was confused and misled to his detriment by the statements in the dunning  letter, and relied on the contents of the letter to his detriment.   75.  Plaintiff would have pursued a different course of action were it not for Defendant’s  statutory violations.   76.  As a result of Defendant’s deceptive, misleading and false debt collection practices,  Plaintiff has been damaged.  77.  Plaintiff repeats the above allegations as if set forth here.   78.  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.   79.  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.   81.  By reason thereof, defendant is liable to Plaintiff for judgment that Defendant’s conduct  violated Section 1692e, et seq. of the FDCPA and Plaintiff is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  82.  Plaintiff repeats the above allegations as if set forth here.   83.  Alternatively, 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.   84.  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.   85.  Defendant violated this section by unfairly misrepresenting Plaintiff’s rights and  misleading Plaintiff as to the proper course of action.   86.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant’s conduct  violated Section 1692f, et seq. of the FDCPA and Plaintiff is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  87.  Plaintiff repeats the above allegations as if set forth here.   88.  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. § 1692g.   89.  Defendant violated this section by failing to provide the proper notice(s) required by  Section 1692g in an initial collection letter.   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.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692g et seq.  