10.  At the time the dunning letter was sent to Plaintiff, Defendant was not and  has never been licensed as a collection agency in the State of Illinois.   11.  Since February 10th, Defendant has contacted Plaintiff’s in order to gather  information to be used in its debt collection activities.   12.  Upon information and belief, Defendant has called Plaintiff numerous  times in attempts to collect debts.   13.  Plaintiff specifically asked Defendant to provide their Illinois license  number.  Defendant failed to provide the requested information.   14.  Defendant took all of the above collection actions against Plaintiff when it  was not licensed as a collection agency in Illinois.  15.  Upon information and belief, it is Defendant’s routine practice to violate the  FDCPA and ICAA by attempting to collect debts in the State of Illinois without being  licensed.   17.  Members of the class are so numerous that joinder is impracticable.   Based on Plaintiff’s research of complaints from other consumers, Defendant is a  high volume debt collector that attempt to collect many thousands of consumer  debts throughout Illinois.     18.  Upon information and belief, Defendant has engaged in the  improper collection communications described above with thousands of  consumers.   19.  Plaintiff is a member of the class she seeks to represent.   20.  There are no unique defenses Defendant can assert against Plaintiff  individually, as distinguished from the class.   21.  Plaintiff will assure the adequate representation of all members of the  class and will have no conflict with class members in the maintenance of this action.   Plaintiff’s interests in this action are typical of the class and are antagonistic to the  interests of the Defendant.  Plaintiff has no interest or relationship with the Defendant  that would prevent her from litigating this matter fully.  Plaintiff is aware that settlement  of a class action is subject to court approval and she will vigorously pursue the class  claims throughout the course of this action.   23.  Most, if not all, the facts needed to determine damages are obtainable  from the Defendants’ records.   24.  The purposes of the FDCPA and ICAA will be best effectuated by a class  action.   25.  A class action is superior to other methods for the fair and efficient  adjudication of this controversy.     26.  Furthermore, as damages suffered by most members of the class are  relatively small in relation to the costs, expense, and burden of litigation, it would be  difficult for members of the class individually to redress the wrongs done to them.     27.  Many, if not all, class members are unaware that claims exist against the  Defendants.  There will be no unusual difficulty in the management of this action as a  class action.   28.  Three common questions of law and fact predominate over all individual  questions in this action.  The common questions are whether: (1) Defendant is a “debt  collector” pursuant to the FDCPA and ICAA; (2) the liabilities that Defendant has sought  to collect from class members constitute “consumer debt” under the FDCPA and ICAA;  and (3) whether Defendant violated the FDCPA and ICAA by attempting to collect debts  in Illinois without being licensed.   30.  Plaintiff and Plaintiff’s counsel have the necessary financial resources to  adequately and vigorously litigate this class action.  Plaintiff’s counsel will fairly and  adequately represent and protect the interests of the Class.   31.  All Class members have been damaged in precisely the same fashion, by  precisely the same conduct.  The loss suffered by individual Class members is  calculable and ascertainable.  32.     Plaintiff re-alleges and incorporates by reference all of the above  paragraphs.   33.    In order to protect consumers, the ICAA creates a licensing regime and  makes it a crime for collection agencies to operate, directly or indirectly engage in the  business of collecting, or exercise the right to collect debts in Illinois without first  obtaining a license.  225 ILCS 425/4; 225 ILCS 425/14.   34.    For every instance in which Defendant demanded payment from an  Illinois consumer for a debt, whether by written correspondence or by telephone or  otherwise, Defendant attempted to do so in violation of the ICAA because Defendant  has never been permitted to collect debts in Illinois.  35.  Plaintiff re-alleges and incorporates by reference all of the above  paragraphs.   9.  On or about February 10, 2015, Plaintiff received a dunning letter from  Defendant attempting to collect an amount due to Uptown Emergency Physicians in the  amount of $55.40.  Exhibit 1.  