21. 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.   22. Some time prior to June 23, 2018, the Plaintiff purchased a vehicle from James Mitsubishi  in Rome, New York, which he financed through an auto loan.   23. Plaintiff has made all of his regular monthly payments on the auto loan.   24. However, Plaintiff was also told to pay an additional $2,000.00 (“the alleged obligation”)  on the auto loan, which he was unable to do, and was given thirty days to pay it.   25. The alleged obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   26. Defendant contends that the alleged obligation is past due.   28. The June 20, 2018 voicemail is a "communication" as defined by 15 U.S.C.§ 1692a(2).   29. Plaintiff has not done anything that would subject him to criminal or civil charges.   30. Defendant never filed any legal charges, criminal or civil, against the Plaintiff.   31. Nor did Defendant ever intend to file any criminal or civil charges against the Plaintiff.   32. Instead, the Defendant simply made up nonsensical threats of legal action and criminal  charges in an attempt to coerce Plaintiff into paying on the alleged obligation, much as  the Defendant has done time and time again to numerous consumers as evinced by the  numerous lawsuits listed above.   33. By making these false threats, the Defendant caused the Plaintiff a real risk of harm.  Plaintiff, as would the least sophisticated consumer, would believe that he had to pay  the alleged debt immediately in order to avoid the serious-sounding consequences  threatened by Defendant.    34. Plaintiff further suffered extreme emotional distress, along with feelings of panic and fear  as a result of the Defendant’s false threats.   35. Moreover, in the Defendant’s voicemail, the Defendant never once stated that it was a  debt collector, that the communication was an attempt to collect a debt, or that any  information obtained would be used for that purpose.     36. Nor has the Defendant ever given that required disclosure to the Plaintiff in any of the  communications that the Defendant had with the Plaintiff.   38. Defendants could have taken the steps necessary to bring its actions within  compliance with the FDCPA, but neglected to do so and failed to adequately  review its actions to ensure compliance with the law.  39. Plaintiff brings claims, pursuant to the Federal Rules of Civil Procedure (hereinafter  “FRCP”) Rule 23, individually and on behalf of the following consumer classes:  Class A:    a) All consumers nationwide, b) whom Defendant falsely threatened with   legal action or criminal charges, c) during the one-year period immediately  preceding the filing of this action.  Class B:    a) All consumers nationwide, b) whom Defendant placed a voicemail to  without disclosing that the communication was from a debt collector, c)  during the one-year period immediately preceding the filing of this action.   40. The identities of all class members are readily ascertainable from the records of Defendant  and those companies and entities on whose behalf they attempt to collect and/or have  purchased debts.   41. Excluded from the Plaintiff Classes 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.   43. The Plaintiff’s claims are typical of the class members, as all are based upon the same facts  and legal theories.   44. The Plaintiff will fairly and adequately protect the interests of the Plaintiff Classes 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 Plaintiff’s  attorneys have any interests, which might cause them not to vigorously pursue this action.   46. 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.   48. 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.   49. 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.   50. Pursuant to 15 U.S.C. § 1692e, a debt collector may not use any false, misleading  and/or deceptive means to collect or attempt to collect any debt or to obtain information  concerning a consumer.   52. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory  damages, costs and attorneys' fees.  53. 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.   54. 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.   55. Pursuant to 15 U.S.C. § 1692e(11), a debt collector must disclose in its initial  communication that the debt collector is attempting to collect a debt and that any  information obtained will be used for that purpose.   56. Pursuant to 15 U.S.C. § 1692e(11), the debt collector must also disclose in subsequent  communications that the communication is from a debt collector.   57. The Defendants violated 15 U.S.C. § 1692e(11) by never once making any of these  required disclosures.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e et seq.  (False Threats And Deceptive Practices)   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   16 U.S.C. §1692e et seq.  (Failure To Provide Required Disclosures)  