10.  The allegations of paragraphs 1 – 9 are incorporated herein as if fully set forth.   11.  The language in Defendants’ letter set forth in paragraph 8, above violated 15 U.S.C.  §1692g(a).   12.  Defendant Jeremy M. Cohen formulated, approved, and/or ratified said language.   14.  There are issues of law and fact common to the class, which issues predominate over  any questions particular to individual class members.  Common issues include whether  Defendants are debt collectors under the FDCPA and whether the subject letter violates  the FDCPA as alleged.   15.  Plaintiff’s claim is typical in that it arises from the same unlawful conduct as the  claims of class members.  Plaintiff and class members seek, and are entitled to, similar  relief.   16.  Plaintiff will fairly and adequately represent the interests of class members.  Plaintiff  is committed to a thorough and vigorous prosecution of this action, and has selected  counsel with substantial experience in consumer class action litigation.  Neither Plaintiff  nor counsel have any conflicts which would interfere with the successful prosecution of  this case.   18.  The allegations of paragraphs 1 – 9 are incorporated herein as if fully set forth.   19.  The language in Defendants’ letter set forth in paragraph 9, above violated 15 U.S.C.  §1692g(a).   20.  Defendant Jeremy M. Cohen formulated, approved, and/or ratified said language.   21.  Plaintiff brings count II of this complaint on behalf of herself and a class of persons  similarly situated.  Class members are all persons to whom either defendant sent an initial  letter concerning a consumer debt within one year prior to the filing of this complaint,  which letter contained the language set forth in paragraph 9, above, and was not returned  or otherwise confirmed as undeliverable.  Excluded from each class are Defendants and  their current and former officers, directors, employees, and agents.  Plaintiff alleges that  Defendants’ standard business practice entailed sending unlawful collection leters to  consumers, as described herein, and therefore Plaintiff further alleges that the members of  the class are sufficiently numerous such that joinder is impracticable.   23.  Plaintiff’s claim is typical in that it arises from the same unlawful conduct as the  claims of class members.  Plaintiff and class members seek, and are entitled to, similar  relief.   24.  Plaintiff will fairly and adequately represent the interests of class members.  Plaintiff  is committed to a thorough and vigorous prosecution of this action, and has selected  counsel with substantial experience in consumer class action litigation.  Neither Plaintiff  nor counsel have any conflicts which would interfere with the successful prosecution of  this case.  