13.  Plaintiff is a natural person obligated, or allegedly obligated, to pay a debt owed  or due, or asserted to be owed or due, a creditor other than ACCT.   14.  Plaintiff's obligation, or alleged obligation, owed or due, or asserted to be owed  or due, a creditor other than ACCT, arises from a transaction in which the money, property,  insurance, or services that are the subject of the transaction were incurred primarily for  personal, family, or household purposes – namely, a GE Capital personal credit card issued  under a JCPenney label (the “Debt”).   15.  On September 11, 2012, Plaintiff, through her counsel, sent a letter via certified  mail to GE Capital notifying it that she was represented by an attorney with respect to the Debt  and demanding that it cease all communications with Plaintiff and direct those communications  instead to her counsel.  See Notice of Representation to GE Capital, attached as Exhibit “A.”   16.  GE Capital received Plaintiff’s notice of representation at 11:57 a.m. on  September 14, 2012.  See Tracking Number Results, attached as Exhibit “B.”    17.  Upon information and belief, ACCT knew that Plaintiff was represented by  counsel with respect to the Debt at the time GE Capital placed the Debt with ACCT.   18.  In the alternative, GE Capital intentionally withheld the fact that Plaintiff was  represented by counsel with respect to the Debt from ACCT.   19.  At some point thereafter, despite its knowledge that Plaintiff was represented by  counsel with respect to the Debt, GE Capital placed the Debt with ACCT for collection.    22.  The Initial Communication does not definitively state whether the Debt is  accruing interest, the rate of interest at which the interest is accruing, or the portion of the Debt  that is principal and the portion of the Debt that is accrued interest or other fees. Id.   23.  Upon information and belief, the Debt is accruing interest.    24.  On January 15, 2013, the Debt had increased to $2,482.38.  See January 15,  2013 Correspondence, attached as Exhibit “D.”   25.  The Initial Communication is therefore susceptible to two reasonable  interpretations.   26.  The Initial Communication also falsely represents the character, amount, or legal  status of the Debt, as prohibited by 15 U.S.C. § 1692e(2)(A).   27.  The Initial Communication also fails to state the amount of the Debt, as required  by 15 U.S.C. § 1692g(a)(1).    28.  ACCT failed to state the amount of the Debt within five days of the Initial  Communication.   33.  Upon information and belief, the Initial Communication is based on a  standardized letter, form, or template.    34.  Upon information and belief, ACCT sent an initial written communication based  on the same standardized letter, form, or template as the Initial Communication to a large  number of Washington consumers from whom ACCT attempted to collect debts over the one  year period before this complaint was filed.    56.  Plaintiff repeats and re-alleges the allegations in paragraphs 1- 55.   65.  Plaintiff repeats and re-alleges the allegations in paragraphs 1- 55.   66.  The FDCPA prohibits “[t]he false representation of—(A) the character, amount,  or legal status of any debt…” 15 U.S.C. § 1692e(2)(A).    67.  ACCT violated 15 U.S.C. § 1692e(2)(A) by failing to state in the Initial  Communication that the Debt was accruing interest.    68.  The Initial Communication violated 15 U.S.C. § 1692e(2)(A) because the “least  sophisticated consumer” could “reasonably conclude that the balance was a fixed amount that  would not be subject to further interest, late fees, or other charges,” or “just as reasonably  determine that the balance would continue to grow over time as interest accrued.” Snyder v.  Daniel N. Gordon, P.C., No. C11-1379 RAJ, 2012 WL 3643673, at *3 (W.D. Wash.).   69.  In addition, or in the alternative, ACCT violated 15 U.S.C. § 1692e(2)(A) by  stating the amount of the Debt as a single sum rather than providing Plaintiff with a breakdown  of the Debt’s accrued interest and other fees.   74.  Plaintiff repeats and re-alleges the allegations in paragraphs 1- 55.   75.  Under § 1692c of the FDCPA, a debt collector “may not communicate with a  consumer in connection with the collection of any debt…if the debt collector knows the  consumer is represented by an attorney with respect to such debt and has knowledge of, or can  readily ascertain, such attorney’s name and address.” 15 U.S.C. § 1692c(a)(2).   76.  ACCT violated 15 U.S.C. § 1692c(a)(2) when it sent Plaintiff the Initial  Communication despite its actual knowledge that Plaintiff was represented by an attorney with  respect to the Debt and when it could readily ascertain the name and address of such attorney  from GE Capital.   78.  Plaintiff repeats and re-alleges the allegations in paragraphs 1- 55.   79.  GE Capital is liable for ACCT’s violation of 15 U.S.C. § 1692c(a)(2), because  GE Capital had actual control over the manner by which ACCT collected the Debt from  Plaintiff, and it intentionally withheld the name and address of Plaintiff’s attorney from ACCT.    80.  In the alternative, GE Capital is liable for ACCT’s violation of 15 U.S.C. §  1692c(a)(2), because GE Capital had actual control over the manner by which ACCT collected  the Debt from Plaintiff, and it knew that ACCT would attempt to collect the Debt from Plaintiff  in spite of its knowledge of Plaintiff’s attorney’s name and address.   81.  In the alternative, GE Capital is liable for ACCT’s violation of 15 U.S.C. §  1692c(a)(2), because GE Capital had actual control over the manner by which ACCT collected  the Debt from Plaintiff, and it knew that ACCT would attempt to collect the debt from Plaintiff  without inquiring whether Plaintiff was represented by an attorney with respect to the Debt.  82.  Plaintiff repeats and re-alleges the allegations in paragraphs 1- 55.   83.  The WCPA declares unlawful “[u]nfair methods of competition and unfair or  deceptive acts or practices in the conduct of any trade or commerce.” RCW § 19.86.020.   AMOUNT CURRENTLY DUE: $420.00   * * * * *  GE Capital Retail Bank may continue to add interest and fees as provided in  your agreement.    Id.    VIOLATION OF 15 U.S.C. § 1692e(2)(A)  ACCT   VIOLATION OF 15 U.S.C. § 1692c(a)(2)  GE CAPITAL    VIOLATION OF 15 U.S.C. § 1692g(a)(1)  ACCT   VIOLATION OF 15 U.S.C. § 1692c(a)(2)  ACCT   VIOLATION OF RCW § 19.86.020  GE CAPITAL  