13.  The debt was incurred by the plaintiff primarily for personal, family, or household  purposes, and is a “debt” as defined by 15 U.S.C. § 1692a(5).   14.  On or about February 23, 2015, Midland sent the plaintiff a copy of the letter  attached hereto, marked as Exhibit A, and incorporated herein by reference.   15.  The letter was a form letter.   16.  In the heading of the letter, Midland states that it is a “PRE-LEGAL  25.  The plaintiff brings this action on behalf of a class of all other persons similarly  situated.   26.  The class consists of all persons who satisfy the following criteria:  a. Massachusetts residents;  b. from whom Midland threatened with legal action in the course of an  attempt to collect a debt;  c. for a debt that was,   i. incurred for personal, family, or household purposes and  ii. time-barred under applicable law;  d. during the one-year period prior to the commencement of this action.   27.  On information and belief, the class is sufficiently numerous that joinder of all  members is impractical.   29.  The plaintiff has the same claims as the members of the class.  All claims are  based on the same factual and legal theories.   30.  The plaintiff and class counsel will fairly and adequately represent the interests of  class members.  There is no reason the plaintiff and her counsel will not vigorously  pursue this matter.     31.  Certification of this class pursuant to Fed. R. Civ. P. 23(b)(3) is appropriate.  A  class action is superior to other available methods for the fair and efficient adjudication of  the controversy, in that:  a. The individual class members are not aware that they have been wronged  and are thus unable to prosecute individual actions;  b. Concentration of the litigation concerning this matter in this Court is  desirable;  c. The claims of the representative plaintiff are typical of the claims of the  class;  d. A failure of justice will result from the absence of a class action; and  e. The class is of moderate size and the difficulties likely to be encountered  in the management of a class action are not great.   32.  Certification of this class pursuant to Fed. R. Civ. P. 23(b)(2) is also appropriate.   The defendant has acted on grounds generally applicable to the class thereby making  declaratory relief appropriate with respect to the class as a whole. 