13. Plaintiff brings claims, pursuant to the Federal Rules of Civil Procedure (hereinafter  “FRCP”) Rule 23, individually and on behalf of the following consumer class (the “Class”)    consisting of:   a) All consumers who have an address in the state of Alabama b) who were sent a  collection letter from the Defendant c) attempting to collect a consumer debt, d)  that states “Unless you notify this office in writing within 30 days after receiving  this notice that you dispute the validity of this debt or any portion thereof, this office  will assume this debt is valid.” (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.   14. The identities of all class members are readily ascertainable from the records of  Defendants and those companies and entities on whose behalf they attempt to collect  and/or have purchased debts.   16. There are questions of law and fact common to the Plaintiff Classes, which common  issues predominate over any issues involving only individual class members. The  principal issue is whether the Defendants’ written communications to consumers, in the  forms attached as Exhibit A, violate 15 U.S.C. §1692e and 1692g.   17. The Plaintiffs’ claims are typical of the class members, as all are based upon the same  facts and legal theories.   18. The Plaintiffs will fairly and adequately protect the interests of the Plaintiff Classes  defined in this complaint. The Plaintiffs have retained counsel with experience in  handling consumer lawsuits, complex legal issues, and class actions, and neither the  Plaintiffs nor their attorneys have any interests, which might cause them not to vigorously  pursue this action.   21. Depending on the outcome of further investigation and discovery, Plaintiffs 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).  22. 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.   23. Some time prior to August 15, 2016, an obligation was allegedly incurred to Radiology  Consultants of N.   24. The alleged Radiology Consultants of N obligation arose out of a transaction in which  money, property, insurance or services, which are the subject of the transaction, are  primarily for medical purposes.   25. The alleged Radiology Consultants of N obligation is a "debt" as defined by 15 U.S.C.§  1692a(5).   26. Radiology Consultants of N is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   27. Defendant contends that the “Radiology Consultants of N” debt is past due.   28. Defendant RS Clark and Associates, Inc. is a company that uses mail, telephone or  facsimile in a business the principal purpose of which is the collection of debts, or that  regularly collects or attempts to collect debts incurred or alleged to have been incurred for  personal, family or household purposes on behalf of creditors.   30. On or about August 15, 2016, the Defendant caused to be delivered to the Plaintiff a  collection letter in an attempt to collect the alleged debt. See Exhibit A.   31. Upon information and belief, the August 15, 2016 letter was the first communication  between the Defendant and Plaintiff regarding the Radiology Consultants of N debt.   32. The August 15, 2016 letter was sent or caused to be sent by persons employed by Defendant  as a “debt collector” as defined by 15 U.S.C. §1692a(6).   33. The August 15, 2016 letter is a “communication” as defined by 15 U.S.C. §1692a(2).   34. The Plaintiff received and read the Letter sometime after August 15, 2016.   35. The Letter stated in part:   “Unless you notify this office in writing within 30 days after receiving this notice  that you dispute the validity of this debt or any portion thereof, this office will  assume this debt is valid.”   36. Upon reading the notice, the Plaintiff, as would any least sophisticated consumer, believed  that the only legally effective way to notify the Defendant that she is disputing the debt  was to do so in writing.   37. Pursuant to 15 U.S.C. §1692g(a)(3) a debt collector must within five days after the initial  communication, send the consumer a written notice containing a statement that if the  consumer notifies the debt collector within 30 days after receiving the notice that the  consumer disputes the validity of the debt or any portion thereof, the debt collector will  assume the debt is valid.    38. Pursuant to 15 U.S.C. §1692g(a)(3), a consumer may dispute the debt, or any portion  thereof, over the phone.   40. Congress further desired to “eliminate the recurring problem of debt collectors dunning the  wrong person or attempting to collect debts which the consumer has already paid.”  S.Rep.  No. 95–382, at 4 (1977), reprinted in 1977 U.S.C.C.A.N. 1695, 1699.   41. By providing an inaccurate validation notice, the Defendant caused the Plaintiff real harm  by depriving her of information to which she was statutorily entitled to receive, by making  it more difficult for the Plaintiff to exercise her dispute rights, by making it less likely that  Plaintiff would dispute her debt, and by subjecting the Plaintiff to deceptive collection  practices which she had a substantive right to be free from.  42. 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.   43. 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. § 1692g.   44. The Defendant violated said provision by failing to accurately convey the validation notice  in violation of 1692g(a)(3).   46. 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.   47. 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.   48. Pursuant to 1692e, a debt collector may not use any false, deceptive or misleading  representation in connection with the collection of a debt.   49. The Defendant violated said section by falsely stating that the Plaintiff could only legally  dispute said debt was in writing in violation of 15 U.S.C. § 1692e(10).   50. 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.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692g et seq.  