65.  Plaintiff re-states, re-alleges and incorporates herein by reference, paragraphs one (1)  through one sixty-four (64) as if set forth fully in this cause of action.   66.  This cause of action is brought on behalf of Plaintiff and the members of a class.   68.  Pursuant to Federal Rule of Civil Procedure 23, a class action is appropriate and preferable  in this case because:  A. The class is so numerous that joinder of all members is impracticable, though  the precise number of class members may be known only to the Defendant.  Plaintiff estimates that each class has thousands of members.  B. There are questions of law and fact common to the class and these questions  predominate over any questions affecting only individual class members. The  principal question presented by this claim is whether the Defendant violated  the FDCPA.  C. The only individual issue is the identification of the consumers who observed  such language in their credit reports, furnished by the Defendant to the credit  bureaus (i.e. the class members), a matter capable of ministerial determination  from the records of Defendant.  D. The claims of the Plaintiff are typical of those of the class members. All are  based on the same facts and legal theories.  E. The Plaintiff will fairly and adequately represent the class members’ interests.  The Plaintiff has retained counsel experienced in bringing class actions and  collection-abuse claims. The Plaintiff's interests are consistent with those of  the members of the class.     70.  If the facts are discovered to be appropriate, the Plaintiff will seek to certify a class  pursuant to Rule 23(b)(3) of the Federal Rules of Civil Procedure.   71.  Collection attempts, such as those made by the Defendant are to be evaluated by the  objective standard of the hypothetical “least sophisticated consumer.”  Violations of the Fair Debt Collection Practices Act   72.  The Defendant’s actions as set forth above in the within complaint violates the Fair Debt  Collection Practices Act.   Violations of the Fair Debt Collection Practices Act brought by Plaintiff on behalf of herself and the  members of a class, as against the Defendant.  