11. Additionally, the phrase “unless you notify this office within thirty 30 days after receiving  this notice that you dispute the validity of this debt, or any portion thereof, this office will  assume this debt is valid” fails to clarify that this dispute must be in writing.    12. Reading the first and second sentence of the validation notice leaves the consumer with  multiple interpretations. Under one interpretation, the consumer will believe that if he or  she disputes the debt orally or in writing, the debt will not be presumed valid. Further, only  if the dispute is made in writing will the debt collector be required to obtain verification of  the debt. But this is not the case. In the Third Circuit, all disputes must be made in writing  to have legal effect under Section g of the FDCPA.   13. Merely quoting the statutory language does not adequately inform the consumer of his or  her rights, let alone the nuances involved in exercising such rights. See Wilson, 255 F.3d at  254; see also McMurray v. ProCollect, Inc., 687 F.3d 665, 668 (5th Cir. 2012) (“Merely  including the required notice in letters to consumers is not sufficient. The notice must also  ‘be set forth in a form and within a context that does not distort of obfuscate its meaning.’”)   (citation omitted).   14. As such, Defendant’s letter is false, deceptive, and misleading in violation of § 1692e and  fails to sufficiently inform the least sophisticated consumer of his or her rights under  §1692g.   15. Plaintiff brings this as a class action pursuant to Fed. R. Civ. P. 23.   17. Excluded from the Class is Defendant herein, and any person, firm, trust, corporation, or  other entity related to or affiliated with the defendant, including, without limitation,  persons who are officers, directors, employees, associates or partners of Defendant.    Numerosity   18. Upon information and belief, Defendant has sent collection letters in an attempt to collect  a debt to hundreds if not thousands of consumers throughout New Jersey, each of which  violates the FDCPA. The members of the Class, therefore, are believed to be so numerous  that joinder of all members is impracticable.   19. The exact number and identities of the Class members are unknown at this time and can  only be ascertained through discovery. Identification of the Class members is a matter  capable of ministerial determination from Defendant’s records.   Common Questions of Law and Fact   21. Plaintiff's claims are typical of the claims of the Class, and Plaintiff has no interests  adverse or antagonistic to the interests of other members of the Class.  Protecting the Interests of the Class Members   22. Plaintiff will fairly and adequately represent the Class members’ interests, in that the  Plaintiff’s counsel is experienced and, further, anticipates no impediments in the pursuit  and maintenance of the class action as sought herein.  Proceeding Via Class Action is Superior and Advisable   23. A class action is superior to other methods for the fair and efficient adjudication of the  claims herein asserted.   24. The members of the Class are generally unsophisticated individuals, whose rights will not  be vindicated in the absence of a class action.   25. Prosecution of separate actions by individual members of the Class would create the risk  of inconsistent or varying adjudications resulting in the establishment of inconsistent or  varying standards for the parties.   26. A class action will permit a large number of similarly situated persons to prosecute their  common claims in a single forum simultaneously, efficiently, and without the duplication  of effort and expense that numerous individual actions would engender. Class treatment  also will permit the adjudication of relatively small claims by many Class members who  could not otherwise afford to seek legal redress for the wrongs complained of herein.   28. Defendant has acted, and will act, on grounds generally applicable to the entire Class,  thereby making appropriate a final injunctive relief or corresponding declaratory relief  with respect to the Class as a whole.  29. Plaintiff repeats the allegations contained in the above paragraphs and incorporates them as  if specifically set forth at length herein.   30. Defendant’s collection letter violates the following provisions of the FDCPA:   31. Section 1692e provides:   § 1692e. False or misleading representations   A debt collector may not use any false, deceptive, or misleading representation  or means in connection with the collection of any debt. Without limiting the  general application of the foregoing, the following conduct is a violation of this  section: . . .   (10) The use of any false representation or deceptive means to collect or  attempt to collect any debt or to obtain information concerning a  consumer…    6. On a date better known by Defendant, Plaintiff incurred debt through use of a credit card  for primarily personal, family, and household purposes from WebBank.   7. In a letter dated February 21, 2018, Defendant sent an initial dunning letter to Plaintiff in  an attempt to collect said debt, attached hereto as Exhibit A.   8. The dunning letter states:   Unless you notify this office within thirty 30 days after receiving this notice that  you dispute the validity of this debt, or any portion thereof, this office will assume  this debt is valid. If you notify this office in writing within 30 days from receiving  this notice that the debt or any portion thereof is disputed, this office will obtain  verification of the debt or obtain a copy of a judgment and mail you a copy of such  judgment or verification. If you request of this office in writing within 30 days after  receiving this notice, this office will provide you with the name and address of the  original creditor, if different from the current creditor.   9. Upon reading the letter, the least sophisticated consumer would not know that the dispute  must be in writing, as mandated by the Third Circuit. See Graziano v. Harrision, 950 F.2d  107 (3d Cir. 1991).    The Class   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692 et seq  