12. Some time prior to January 9, 2018, an obligation was allegedly incurred to Chase Bank  USA, N.A.   13. The Chase Bank USA, N.A. obligation arose out of a transaction in which money, property,  insurance or services, which are the subject of the transaction, are primarily for personal,  family or household purposes.   14. The alleged Chase Bank USA, N.A. obligation is a "debt" as defined by 15 U.S.C.§  1692a(5).   15. Chase Bank USA, N.A. is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   16. On or about January 9, 2018, Defendant sent a letter (the “Letter”) to the Plaintiff a  collection letter regarding the alleged debt. See Exhibit A.   17. Upon information and belief, this Letter was the first communication between Defendant  and the Plaintiff regarding the alleged debt.   18. Plaintiff received the letter and read it.   19. The Letter states offered Plaintiff a discount but warned the Plaintiff should she want  favorable terms from Chase in the future, she would have to pay the full balance.   20. Specifically the letter stated:  “If we settle this debt with you for less than the full outstanding balance, Chase  may offer you less favorable terms in the future for some Chase products or  services, or may deny your application.”   21. Plaintiff, as would any least sophisticated consumer, read the above statement to mean two  things: (1) if Plaintiff pays less than full balance, Chase will offer me less favorable terms  and (2) should Plaintiff pay the full amount of the alleged debt, Chase will offer favorable  terms in the future.   22. Upon information and belief, had Plaintiff paid the full amount, she would not have been  offered more favorable terms in the future.   23. The language was used to mislead the Plaintiff into believing she had a financial incentive  to pay the full amount, when none existed.   24. Furthermore, Defendant was in no position nor are they able to ascertain whether paying  this alleged debt would improve Plaintiff’s credit reports and credit scores.   25. According to guidance published by the Consumer Financial Protection Bureau  (hereinafter “CFPB”), a debt collector’s representation to a consumer that paying debts  may improve the consumer’s creditworthiness or “enhance the likelihood that a consumer  will subsequently receive credit from a lender” may be deceptive. CFPB Bulletin 2013-08  – Representations Regarding Effect of Debt Payments on Credit Reports and Scores (July  10, 2013). See Exhibit B.   26. By inputting this language, the Defendant caused the Plaintiff a real risk of harm.  Plaintiff, as would the least sophisticated consumer, would believe that they have a  financial incentive to pay more, when no financial incentive existed.   27. As a result of the Defendant’s violations of the FDCPA, the Plaintiff was harmed.    28. Defendant’s actions as described herein are part of a pattern and practice used to collect  consumer debts.  29. Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ. P. 23(a)  and 23(b)(3).   30. The Class consists of (a) all individuals with addresses in the state of New York (b) to  whom Defendant (c) sent a collection letter attempting to collect a consumer debt owed to  Chase Bank USA, N.A. (d) which stated “If we settle this debt with you for less than the  full outstanding balance, Chase may offer you less favorable terms in the future for some  Chase products or services, or may deny your application.” (e) which letter was sent on or  after a date one year prior to the filing of this action and on or before a date 21 days after  the filing of this action.   31. The identities of all class members are readily ascertainable from the records of Defendant  and those companies and entities on whose behalf they attempt to collects and/or have  purchased debts.   32. Excluded from the Plaintiff Class are the Defendant and all officers, members, partners,  managers, directors, and employees of the Defendant and their respective immediate  families, and legal counsel for all parties to this action and all members of their immediate  families.   33. 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 Defendant’s written communications to consumers, in the forms attached as  Exhibits A, violate 15 U.S.C. §§ 1692e.   34. The Plaintiff’s claims are typical of the class members, as all are based upon the same facts  and legal theories.   35. The Plaintiff will fairly and adequately protect the interests of the Plaintiff Class defined  in this complaint. The Plaintiff has retained counsel with experience in handling consumer  lawsuits, complex legal issues, and class actions, and neither the Plaintiff nor Plaintiff’s  attorneys have any interests, which might cause them not to vigorously pursue this action.   36. This action has been brought, and may properly be maintained, as a class action pursuant  to the provisions of Rule 23 of the Federal Rules of Civil Procedure because there is a well- defined community interest in the litigation:  (a)  Numerosity: The Plaintiff is informed and believes, and on that basis alleges, that  the Plaintiff Class defined above is so numerous that joinder of all members would  be impractical.  (b)  Common Questions Predominate: Common questions of law and fact exist as to  all members of the Plaintiff Class and those questions predominate over any  questions or issues involving only individual class members. The principal issue is  whether the Defendant’s written communications to consumers, in the forms  attached as Exhibit A, violate 15 U.S.C. §§ 1692e.  (c)  Typicality: The Plaintiff’s claims are typical of the claims of the class members.  The Plaintiff and all members of the Plaintiff Class have claims arising out of the  Defendant’s common uniform course of conduct complained of herein.  (d)  Adequacy: The Plaintiff will fairly and adequately protect the interests of the class  members insofar as Plaintiff has no interests that are adverse to the absent class  members. The Plaintiff is committed to vigorously litigating this matter. Plaintiff  has also retained counsel experienced in handling consumer lawsuits, complex  legal issues, and class actions. Neither the Plaintiff nor Plaintiff’s counsel has any  interests which might cause them not to vigorously pursue the instant class action  lawsuit.  (e)  Superiority: A class action is superior to the other available means for the fair and  efficient adjudication of this controversy because individual joinder of all members  would be impracticable. Class action treatment will permit a large number of  similarly situated persons to prosecute their common claims in a single forum  efficiently and without unnecessary duplication of effort and expense that  individual actions would engender.   37. 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.   38. 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).  39. 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.   40. Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff violated  various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   41. 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.     42. Defendant violated said section by:  • Falsely representing the amount of the debt in violation of §1692e(2)  • Making a false and misleading representation in violation of §1692e(10).   43. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's 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.  