18.  UNIVERSAL regularly collects, and attempts to collect, defaulted debts incurred,  or alleged to have been incurred, for personal, family, or household purposes on behalf of  creditors using the U.S. Mail, telephone, and Internet.   19.  By letter dated June 19, 2017 (“Long Letter”), UNIVERSAL attempted to collect  from LONG an allegedly defaulted financial obligation that arose out of a transaction in which  the money, property, insurance, or services which were the subject of the transaction were  incurred for personal, family, and household purposes.   20.  A true copy of the Long Letter is attached as Exhibit A except that the  undersigned counsel has, in accordance with Fed. R. Civ. P. 5.2, partially redacted the financial  account numbers to protect LONG’s privacy.   21.  On information and belief, UNIVERSAL obtained the financial obligation (“Long  Debt”) described in Exhibit A for collection purposes after it was in default.   22.  It is unknown if Exhibit A is the initial letter UNIVERSAL sent LONG regarding  the Long Debt.   23.  On information and belief, Exhibit A is a computer-generated, template form  letter that UNIVERSAL uses to collect debts.   24.  Page One of Exhibit A refers to UNIVERSAL’s client, but never identifies the  creditor.   26.  The FDCPA in 15 U.S.C. § 1692c requires a debt collector to stop contacting a  consumer when a consumer notifies a debt collector in writing that they (i) refuse to pay a debt,  or (ii) wish the debt collector cease further communication with the consumer.   27.  Exhibit A deprived LONG of truthful, non-misleading, information in connection  with UNIVERSAL’s attempt to collect a debt.   28.  By letter dated January 4, 2018 (“Volkman January Letter”), UNIVERSAL  attempted to collect from VOLKMAN an allegedly defaulted financial obligation that arose out  of a transaction in which the money, property, insurance, or services which were the subject of  the transaction were incurred for personal, family, and household purposes.   29.  A true copy of the Volkman January Letter is attached as Exhibit B except that  the undersigned counsel has, in accordance with Fed. R. Civ. P. 5.2, partially redacted the  financial account numbers to protect VOLKMAN’s privacy.   30.  On information and belief, UNIVERSAL obtained the financial obligation  (“Volkman Debt”) described in Exhibit B for collection purposes after it was in default.   31.  It is unknown if Exhibit B is the initial letter UNIVERSAL sent VOLKMAN  regarding the Volkman Debt.   32.  On information and belief, Exhibit B is a computer-generated, template form  letter that UNIVERSAL uses to collect debts.   33.  Page One of Exhibit B refers to “Bradford Authenticated” and states that  UNIVERSAL was asked by “Bradford Authenticated” to contact VOLKMAN “regarding [his]  account.”   35.  Exhibit B does not identify the creditor of the Volkman Debt.   36.  Exhibit B also states “there is still time to respond in order to prevent further  contact by Universal Fidelity LP.”    37.  The FDCPA in 15 U.S.C. § 1692c requires a debt collector to stop contacting a  consumer when a consumer notifies a debt collector in writing that they (i) refuse to pay a debt,  or (ii) wish the debt collector cease further communication with the consumer.   38.  By letter dated February 15, 2018 (“Volkman February Letter”), UNIVERSAL  attempted to collect from VOLKMAN the Volkman Debt.   39.  A true copy of the Volkman February Letter is attached as Exhibit C except that  the undersigned counsel has, in accordance with Fed. R. Civ. P. 5.2, partially redacted the  financial account numbers to protect VOLKMAN’s privacy.   40.  It is unknown if Exhibit C is the initial letter UNIVERSAL sent VOLKMAN  regarding the Volkman Debt.   41.  On information and belief, Exhibit C is a computer-generated, template form  letter that UNIVERSAL uses to collect debts.   42.  Page One of Exhibit C refers to “Bradford Authenticated,” identifies an “Account  No.” and then states “[t]he debt that you owe to the above-referenced client has been placed with  Universal Fidelity LP….”   43.  There is no “client” referenced on Exhibit C.   44.  Page One of Exhibit C then instructs VOLKMAN to mail a payment “made  payable to UFLP.”   46.  Exhibits B and C deprived VOLKMAN of truthful, non-misleading, information  in connection with UNIVERSAL’s attempt to collect a debt.   47.  The reverse side of Exhibits A, B, and C all contain the following statement:   48.  Exhibits A, B, and C state that the consumer has the right to seek validation of the  debt “within 30 days after receiving your initial notice that you dispute the validity of this debt or  any portion thereof . . . .” but do not state whether Exhibits A, B, and C are the “initial notice.”   49.  Exhibits A, B, and C mislead the unsophisticated consumer to believe the  validation period began before receiving Exhibits A, B, and C and had, potentially, already  expired.   50.  An unsophisticated consumer could understand “your initial notice” to mean the  initial validation notice, was provided by some other debt collector that had previously collected  on the same debt. See, e.g., Sanchez v. Jackson, 2016 U.S. Dist. LEXIS 160776, at *27 (N.D. Ill.  Nov. 21, 2016) (“the notification provisions of § 1692g apply to the initial communication made  in connection with the collection of a debt by each successive debt collector.”)   53.  This action is brought as a class action. Plaintiffs bring this action on behalf of  themselves and on behalf of all other persons similarly situated pursuant to Rule 23 of the  Federal Rules of Civil Procedure.   54.  Plaintiffs seek to certify a class pursuant to Fed. R. Civ. P. 23(a) and (b)(3).   55.  This claim is brought on behalf of a Class of all persons to whom UNIVERSAL  mailed a written communication that was not returned as undeliverable, to an address in the State  of Wisconsin, during the period of June 19, 2017 through July 10, 2018, in an attempt to collect a  defaulted account, and which states:    56.  The identities of the Class members are readily ascertainable from  UNIVERSAL’s business records.   57.  The Class claims include all claims Class members may have for a violation of  the FDCPA based on a letter from UNIVERSAL, such as Exhibits A, B, and C, which seek to  collect defaulted debts.   60.  Based on discovery and further investigation (including, but not limited to,  UNIVERSAL’s disclosure of class size and net worth), Plaintiffs may, in addition to moving for  class certification using modified definitions of the class, class claims, and the class period,  and/or seek class certification only as to particular issues as permitted under Fed. R. Civ. P.  23(c)(4). Such modified definitions may be more expansive to include/exclude consumers from  the foregoing definitions.  61.  Plaintiffs reallege and incorporate by reference the allegations in the preceding  paragraphs of this Complaint.   62.  UNIVERSAL is a “debt collector” as defined by 15 U.S.C. § 1692a(6).   63.  Exhibit A is a “communication” as defined by 15 U.S.C. § 1692a(2).    64.  Exhibit B is a “communication” as defined by 15 U.S.C. § 1692a(2).   65.  Exhibit C is a “communication” as defined by 15 U.S.C. § 1692a(2).   66.  The Long Debt is a “debt” as defined by 15 U.S.C. §1692a(5).   67.  The Volkman Debt is a “debt” as defined by 15 U.S.C. §1692a(5)   68.  LONG is a “consumer” as defined by 15 U.S.C. § 1692a(3).   69.  VOLKMAN is a “consumer” as defined by 15 U.S.C. § 1692a(3).   70.  Exhibit A was mailed to LONG to collect the Long Debt.   71.  Exhibit B was mailed to VOLKMAN to collect the Volkman Debt.   72.  Exhibit C was mailed to VOLKMAN to collect the Volkman Debt.   74.  UNIVERSAL’s use of Exhibits A, B, and C violated the FDCPA in one or more  following ways:  (a)  Using false, deceptive, and misleading representations or means in  connection with the collection of any debt in violation of 15 U.S.C. § 1692e  including, but not limited to, violations of §§ 1692e(2), 1692e(10), and  1692g(a); and  (b)  Failing to identify the name of the creditor to whom the debt is owed in  violation of 15 U.S.C. § 1692g(a)(2).  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  