19. 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.   20. Some time prior to January 07, 2016, an obligation was allegedly incurred by Plaintiff to  Capital One, N.A..   21. The Capital One, N.A. obligation arose out of an alleged claim for unpaid student loans, a  transaction in which money, property, insurance or service, which are the subject of the  transaction, are primarily for personal, family or household purposes.   22. The alleged Capital One, N.A. obligation is a "debt" as defined by 15 U.S.C. §1692a(5).   23. Capital One, N.A. is a "creditor" as defined by 15 U.S.C. §1692a(4).   24. On or about January 31, 2015, Capital One, N.A. charged off the alleged debt.   25. Upon information and belief, at the time the alleged debt was charged off, Capital One,  N.A. had no intention of continuing to charge interest on the account.   26. Sometime after January 31, 2015, Capital One, N.A. sold the alleged debt to BIGP.   27. BIGP directly or through an intermediary contracted CCLLC to collect the alleged debt.   28. Defendants contend that the alleged debt is in default.   29. Defendants collect and attempt to collect debts incurred or alleged to have been incurred  for personal, family or household purposes on behalf of creditors using the United States  Postal service, telephone and internet.   30. On or about January 07, 2016, the Defendant caused to be delivered to the Plaintiff a  collection letter (the “Letter”) in an attempt to collect the alleged debt. See Exhibit A.   32. The Letter is a “communication” as defined by 15 U.S.C. §1692a(2).   33. The Letter attempts to provide the Validation Notice as required by 15 U.S.C. §1692g by  stating in part:  If you notify this office in writing within 30 days from receiving this notice, this office  will obtain verification of the debt or obtain a copy of a judgment and mail you a copy of  such verification or judgment.   34. The Plaintiff, as would any least sophisticated consumer, read the above statement and  inferred that the only way to obtain verification of the debt or a copy of a judgment, the  Plaintiff must dispute the entirety of the debt.   35. As the alleged debt includes principal, interest, and possibly other charges, the Plaintiff  very likely may have a dispute regarding only a portion of the alleged balance.    36. By failing to notify the Plaintiff of his right to dispute a portion of the debt, the Plaintiff,  along with other consumers, may be left confused which will cause them to lose their  validation rights.   37. On information and belief, Defendant sent a written communication, in the form annexed  hereto as Exhibit A to at least 50 natural persons in the United States within one year of  the date of this Complaint.  38. 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. 15 U.S.C. § 1692g(a) sets forth the Validation Notice requirements incumbent on  collection agencies and debt collection law firms.  That provision states:  Within five days after the initial communication with a consumer in connection with the  collection of any debt, a debt collector shall, unless the following information is  contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing—  (1) the amount of the debt;  (2) the name of the creditor to whom the debt is owed;  (3) a statement that unless the consumer, within thirty days after receipt of the  notice, disputes the validity of the debt, or any portion thereof, the debt will be  assumed to be valid by the debt collector;  (4) a statement that if the consumer notifies the debt collector in writing within  the thirty-day period that the debt, or any portion thereof, is disputed, the debt  collector will obtain verification of the debt or a copy of a judgment against the  consumer and a copy of such verification or judgment will be mailed to the  consumer by the debt collector; and  (5) a statement that, upon the consumer’s written request within the thirty-day  period, the debt collector will provide the consumer with the name and address of  the original creditor, if different from the current creditor.   41. Pursuant to 15 U.S.C. § 1692g(a)(4), a debt collector must notify a debtor that - in order  for a debtor to trigger his rights to obtain verification of the subject debt – the debtor  must notify the debt collector in writing within the thirty-day period that the debt, or any  portion thereof, is disputed.    42. The Letter failed to comply with the requirements of 15 U.S.C. § 1692g(a)(4), where it  failed to make any mention of the statutory requirement of that provision, specifically  that in order for the Plaintiff to trigger her rights to obtain verification of the subject debt,  the Plaintiff should notify the Defendant that the debt, or any portion thereof, is disputed.    44. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's conduct  violated Section 1692g 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. §1692g et seq.  