21.  Defendant alleges Plaintiff owes a debt (“the alleged Debt”).     22.  The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of  a transaction in which the money, property, insurance, or services which are the subject of the  transaction are primarily for personal, family, or household purposes.  4   23.  The alleged Debt does not arise from any business enterprise of Plaintiff.   24.  The alleged Debt is a “debt” as defined by 15 U.S.C. § 1692a(5).   25.  At an exact time known only to Defendant, the alleged Debt was assigned or  otherwise transferred to Defendant for collection.    26.  At the time the alleged Debt was assigned or otherwise transferred to Defendant  for collection, the alleged Debt was in default.   27.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff by two  letters both dated December 8, 2018. (True and accurate copies of the letters are annexed hereto  as “Exhibit 1.”)   28.  The letters conveyed information regarding the alleged Debt.   29.  The letters are “communications” as defined by 15 U.S.C. § 1692a(2).    30.  The letters were the initial written communications Plaintiff received from  Defendant concerning the alleged Debt.   31.  The letters were received and read by Plaintiff.   32.  15 U.S.C. § 1692g protects Plaintiff's concrete interests.  Plaintiff has the interest  and right to receive a clear, accurate and unambiguous validation notice, which allows a  consumer to confirm that he or she owes the debt sought to be collected by the debt collector.  As  set forth herein, Defendant deprived Plaintiff of this right.   33.  15 U.S.C. § 1692e protects Plaintiff's concrete interests. Plaintiff has the interest  and right to be free from deceptive and/or misleading communications from Defendant. As set  forth herein, Defendant deprived Plaintiff of this right.   34.  The deprivation of Plaintiff's rights will be redressed by a favorable decision  herein.  35.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     36.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.  5   37.  As relevant here, 15 U.S.C. § 1692g(a)(1) requires the written notice provide “the  amount of the debt.”   38.  To comply with 15 U.S.C. § 1692g(a)(1), a statement of “the amount of the debt”  must clearly convey, from the perspective of the least sophisticated consumer, the actual amount  of the debt.   39.  To comply with 15 U.S.C. § 1692g(a)(1), a statement of “the amount of the debt”  must convey without ambiguity, from the perspective of the least sophisticated consumer, the  actual amount of the debt.   40.  The letters are for the same credit card ending in 11006.   41.  The letters have different balances for the same credit card.   42.  The first letter states the balance is $8,082.07, and the second letter states the  balance is $1,113.75.     43.  The least sophisticated consumer would be unsure whether the balance owed is  $8,082.07 or $1,113.745.     44.  The least sophisticated consumer would be confused as to whether the balance  owed is $8,082.07 or $1,113.745.     45.  The least sophisticated consumer would be unable to determine as to whether the  amount of the alleged Debt is $8,082.07 or $1,113.745.   46.  As a result, Defendant did not clearly convey, from the perspective of the least  sophisticated consumer, the actual amount of the alleged Debt as required by 15 U.S.C. §  1692g(a)(1).    47.  As a result, Defendant did not accurately convey, from the perspective of the least  sophisticated consumer, the actual amount of the alleged Debt as required by 15 U.S.C. §  1692g(a)(1).    48.  As a result, Defendant did not convey without ambiguity, from the perspective of  the least sophisticated consumer, the actual amount of the alleged Debt as required by 15 U.S.C.  § 1692g(a)(1).    49.  For the foregoing reasons, Defendant violated 15 U.S.C. § 1692g(a)(1) and is  liable to Plaintiff therefor.  6  50.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.   51.  15 U.S.C. § 1692e provides, generally, that a debt collector may not use any false,  deceptive, or misleading representation or means in connection with the collection of any debt.    52.  15 U.S.C. § 1692e(2)(A) prohibits the false representation of the character,  amount, or legal status of any debt.   53.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     54.  A debt collection practice can be a “false, deceptive, or misleading” practice in  violation of 15 U.S.C. § 1692e even if it does not fall within any of the subsections of 15 U.S.C.  § 1692e.  Clomon, 988 F.2d at 1318.    55.  A collection letter violates 15 U.S.C. § 1692e if, in the eyes of the least  sophisticated consumer, it is open to more than one reasonable interpretation, at least one of  which is inaccurate. Clomon, 988 F.2d at 1319.   56.  A  collection  letter  also  violates  15  63.  Plaintiff brings this action individually and as a class action on behalf of all  7  persons similarly situated in the State of New York.   64.  Plaintiff seeks to certify a class of:  All consumers to whom Defendant sent a collection letter  substantially and materially similar to the Letter sent to Plaintiff,  which letter was sent on or after a date one year prior to the filing of  this action to the present.   65.  This action seeks a finding that Defendant's conduct violates the FDCPA, and  asks that the Court award damages as authorized by 15 U.S.C. § 1692k.   66.  The Class consists of more than thirty-five persons.   67.  Plaintiff's claims are typical of the claims of the Class.  Common questions of law  or fact raised by this action affect all members of the Class and predominate over any individual  issues.  Common relief is therefore sought on behalf of all members of the Class.  A class action  is superior to other available methods for the fair and efficient adjudication of this controversy.   68.  The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of the  Class, and a risk that any adjudications with respect to individual members of the Class would, as  a practical matter, either be dispositive of the interests of other members of the Class not party to  the adjudication, or substantially impair or impede their ability to protect their interests.   Defendant has acted in a manner applicable to the Class as a whole such that declaratory relief is  warranted.   69.  Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class is not extraordinarily difficult, and the factual and legal issues  raised by this action will not require extended contact with the members of the Class, because  Defendant's conduct was perpetrated on all members of the Class and will be established by  common proof.  Moreover, Plaintiff has retained counsel experienced in actions brought under  consumer protection laws.  Violations of 15 U.S.C. §§ 1692e, 1692e(2)(A) and 1692e(10)   Violation of 15 U.S.C. § 1692g(a)(1)  