10. On or about October 12, 2012, Plaintiff received another phone call on his cellular  telephone, and the same number appeared on his phone’s caller identification: 1-888-613- 0232.    11. Plaintiff again declined to answer the call, and received a voicemail recording of the  same pre-recorded message transcribed in ¶ 8, supra.   12. Because the caller placed a telephone call without meaningful disclosure of its  identity, the communication constituted a violation of 15 U.S.C. § 1692d(6).   13. On or around November 17, 2012, Plaintiff called the phone number that had  appeared on his caller identification, and that was left in the voicemails described  supra: 1-888-613-0232   14.  A woman answered the phone, and identified herself as an agent of Defendant— Stellar Recovery, Inc.   15.  Defendant’s agent told Plaintiff that Defendant was seeking $234.00 from him,  for a debt that Plaintiff allegedly owed to Comcast.   17. On information and belief, Defendant placed telephone calls to numerous other  Minnesota consumers without the meaningful disclosure of its identity, as part of  the collection campaigns that included the calls to Plaintiff on or around October  4, 2012, and on or around October 12, 2012, and in doing so, violated 15 U.S.C.  1692d(6) each and every time.   18. Plaintiff brings this action individually and as a Class for Defendant’s violations of  the FDCPA, including 15 U.S.C. § 1692d(6), pursuant to Federal Rules of Civil  Procedure 23b(2) and 23b(3), on behalf of the following Class:  All Minnesota consumers to whom Defendant placed phone calls  without meaningful disclosure of its identity, on or around October  4, 2012 and/or on or around October 12, 2012.   19. The Class is so numerous that joinder of all members is impracticable. Although  only Defendant knows the number and identity of Class members, Plaintiff, on  information and belief, asserts that the number of Class members is in the  hundreds, if not thousands.    20. There are questions of law and fact common to the Class. The central question is  whether, as required by 15 U.S.C. § 1692d(6), Defendant meaningfully disclosed  its identity when it placed telephone calls to Class members on or around October  4, 2012, and/or on or around October 12, 2012.    22. Plaintiff and his counsel will fairly and adequately protect the interests of the  Class. Plaintiff is committed to vigorously litigating this matter, and has secured  counsel experienced in consumer class action litigation, including FDCPA  litigation. Neither Plaintiff nor his counsel has any interests that might cause either  of them to fail to vigorously pursue this action.    23. This action should be maintained as a class action, because the prosecution of  separate actions by individual members of the putative Class would create a risk of  inconsistent or varying adjudications with respect to individual members, which  would establish incompatible standards of conduct for the parties opposing this  class, as well as a risk of adjudications with respect to individual members which  would, as a practical matter, be dispositive of the interests of other members not  parties to the adjudications, or substantially impair or impede their ability to  protect their interests.   25. Questions of law or fact common to class members predominate over any  questions affecting only individual members, and a class action is superior to other  available methods for fairly and efficiently adjudicating this controversy.   26. The interest of Class members in individually controlling the prosecution of  separate claims against Defendant is small. Management of the Class claims is  likely to present significantly fewer difficulties than those presented in many  individual claims. The identities of the Class members may be obtained from  Defendant’s records.   28.  Plaintiff incorporates by reference the above paragraphs as though fully stated herein.   29.  The foregoing acts and omissions of Defendant constitute violations of the Fair Debt  Collection Practices Act (“FDCPA”), specifically 15 U.S.C. § 1692d(6).   31.  As a result of the Defendant’s violations of the FDCPA, it is liable to Plaintiff and Class  members for statutory damages, costs, and reasonable attorney’s fees, pursuant to 15  U.S.C. § 1692k.  5. Sometime in or around September 2011, Plaintiff signed up for cable and internet  services from Comcast Corporation (“Comcast”) at his then-residence, an apartment at  the address of 6301 Quinwood Lane North, Maple Grove, MN 55369.    6.  In or around June 2012, Plaintiff sub-leased his apartment at 6301 Quinwood Lane  North, moved to a different address, and cancelled his cable and internet services from  Comcast.    7. On or about October 4, 2012, Plaintiff received a phone call on his cellular  telephone, and the number that appeared on his cellular telephone’s caller  identification was: 1-888-613-0232.   9. Because the caller placed a telephone call without meaningful disclosure of its  identity, the communication constituted a violation of 15 U.S.C. § 1692d(6).   COUNT I.  VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C.  § 1692 et seq.   