13. Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ. P. 23(a)  and 23(b)(3).   15. The identities of all class members are readily ascertainable from the records of Defendants  and those companies and entities on whose behalf they attempt to collect and/or have purchased  debts.   16. Excluded from the Plaintiff Class are the Defendants and all officer, members, partners,  managers, directors and employees of the Defendants and their respective immediate families, and  legal counsel for all parties to this action, and all members of their immediate families.    17. There are questions of law and fact common to the Plaintiff Class, which common issues  predominate over any issues involving only individual class members. The principal issue is whether  the Defendants’ written communications to consumers, in the forms attached as Exhibit A, violate  15 U.S.C. §§ 1692e & 1692g.   18. Plaintiff’s claims are typical of the class members, as all are based upon the same facts and  legal theories. Plaintiff will fairly and adequately protect the interests of the Plaintiff Class defined  in this complaint. Plaintiff has retained counsel with experience in handling consumer lawsuits,  complex legal issues, and class actions, and neither Plaintiff nor her attorneys have any interests,  which might cause them not to vigorously pursue this action.   20. Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure is also  appropriate in that the questions of law and fact common to members of the Plaintiff Class  predominate over any questions affecting an individual member, and a class action is superior to  other available methods for the fair and efficient adjudication of the controversy.   21. Depending on the outcome of further investigation and discovery, Plaintiff may, at the time  of class certification motion, seek to certify a class(es) only as to particular issues pursuant to Fed.  R. Civ. P. 23(c)(4).  22. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length herein.   23. Some time prior to February 10, 2021, an obligation was allegedly incurred to HSBC Bank  Nevada, N.A.   24. The HSBC Bank Nevada, N.A. obligation arose out of a transaction in which involved the  transaction of money, property, insurance or services primarily for personal, family or household  purposes.    25. The alleged HSBC Bank Nevada, N.A. obligation is a "debt" as defined by 15 U.S.C.§  1692a(5).   26. HSBC Bank Nevada, N.A. is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   27. Defendant LVNV, a debt collector and subsequent owner of the HSBC Bank Nevada, N.A.  debt, contracted with Defendant TrueAccord to collect the alleged debt.   29. On or about February 10, 2021, Defendant TrueAccord sent Plaintiff a collection letter (the  “Letter”) regarding the alleged debt owed. A true and accurate copy of the Letter is attached as  Exhibit A.   30. The Letter states a balance of $731.92.   31. The Letter further states: “The law limits how long you can be sued on a debt.  Because of  the age of your debt, LVNV Funding LLC cannot report it to any credit reporting agency.”   32. The Letter is materially deceptive as it fails to disclose that the previously-lapsed statute of  limitations to file a lawsuit to collect the debt will recommence upon payment by Plaintiff.   33. Therefore, the Letter puts the Plaintiff at material risk of making a partial payment and  thereby unknowingly recommencing the lapsed statute of limitations.   34. Plaintiff sustained an informational injury in that she was deceptively misled about the true  legal nature of the alleged debt and was not advised that making payment on the debt would restart  the statute of limitations.   35. As a result of Defendants’ deceptive, misleading and unfair debt collection practices,  Plaintiff has been damaged.  36. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs above  herein with the same force and effect as if the same were set forth at length herein.   38. Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   39. Defendants violated §1692e:   a. by omitting material information creating a false and misleading representation of  the status of the debt in violation of §1692e(10); and  b. by falsely representing the character, amount or legal status of the debt in violation  of §1692e(2)(A).   40. By reason thereof, Defendants are liable to Plaintiff for judgment that Defendants conduct  violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs and  attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692e et seq.  