Defendant.  =======================================   CLASS ACTION COMPLAINT  Introduction  1)  Plaintiff Tova Hartman files this Complaint seeking redress for the illegal  practices of Defendant First Step Group, LLC who, inter alia, used false, deceptive,  and misleading practices, and other illegal practices, in connection with its attempts to  collect an alleged debt from the Plaintiff and others, in violation of the Fair Debt  Collection Practices Act, ("FDCPA"), 15 U.S.C. § 1692, et seq. (“FDCPA”).   2)  The Plaintiff alleges that Defendant's collection practices violate the Fair  Debt Collection Practices Act, 15 U.S.C. § 1692, et seq. (“FDCPA”).  Such collection  practices include, inter alia:   (a)  Leaving messages for consumers, which fail to provide meaningful  disclosure of Defendant's identity;  -2-  (b)  Leaving messages for consumers, which fail to disclose that the call  is from a debt collector; and   (c)  Leaving messages for consumers, which fail to disclose the purpose  or nature of the communication (i.e. an attempt to collect a debt).   3)  The FDCPA regulates the behavior of collection agencies attempting to  collect a debt on behalf of another. The United States Congress has found abundant  evidence of the use of abusive, deceptive, and unfair debt collection practices by many  debt collectors, and has determined that abusive debt collection practices contribute to  a number of personal bankruptcies, marital instability, loss of jobs, and invasions of  individual privacy. Congress enacted the FDCPA to eliminate abusive debt collection  practices by debt collectors, to ensure that those debt collectors who refrain from using  abusive debt collection practices are not competitively disadvantaged, and to promote  uniform State action to protect consumers against debt collection abuses.  15 U.S.C. §  1692(a) - (e).  4)  The FDCPA is a strict liability statute, which provides for actual or  statutory damages upon the showing of one violation. The Second Circuit has held that  whether a debt collector's conduct violates the FDCPA should be judged from the  standpoint of the "least sophisticated consumer."1  5)  To prohibit harassment and abuses by debt collectors, the FDCPA, at 15  U.S.C. § 1692d, provides that a debt collector may not engage in any conduct the  natural consequence of which is to harass, oppress, or abuse any person in connection  with the collection of a debt and names a non-exhaustive list of certain per se violations  1 Clomon v. Jackson, 988 F.2d 1314 (2d Cir. 1993).  -3-  of harassing and abusive collection conduct.  15 U.S.C. § 1692d(l)-(6).  Among the per  se violations prohibited by that section are: the placement of telephone calls without  meaningful disclosure of the caller's identity.  15 U.S.C. § 1692d(6).   6)  To prohibit deceptive practices, the FDCPA, at 15 U.S.C. § 1692e,  outlaws the use of false, deceptive, and misleading collection practices and names a  non-exhaustive list of certain per se violations of false and deceptive collection  conduct.  15 U.S.C. § 1692e(1)-(16).  Among the per se violations prohibited by that  section are: using any false representation or deceptive means to collect or attempt to  collect any debt or to obtain information concerning a consumer, 15 U.S.C. §  1692e(10); the failure by debt collectors to disclose in initial oral communications that  the debt collector is attempting to collect a debt and that any information obtained will  be used for that purpose, 15 U.S.C. § 1692e(11); and the failure by debt collectors to  disclose in subsequent oral communications that the communication is from a debt  collector, 15 U.S.C. § 1692e(11).2  Parties  7)  At all times relevant to this lawsuit, Plaintiff is a citizen of the State of New  York who resides within this District.  8)  Plaintiff is a consumer as that term is defined by Section 1692(a)(3) of the 