10. In doing so, Defendant disclosed Plaintiff’s personal information to a third party in violation  of the FDCPA.   11.  Plaintiff brings this as a class action pursuant to Fed. R. Civ. P. 23.   12.  Plaintiff seeks certification of the following class, initially defined as follows:  Class: All consumers residing within the United States that have received a letter from  Defendant via a third-party vendor concerning debts used primarily for personal, household,  or family purposes, within one year prior to the filing of this Complaint.   13.  Excluded from the Class is Defendant, and any person, firm, trust, corporation, or other  entity related to or affiliated with Defendant, including, without limitation, persons who are  officers, directors, employees, associates or partners of Defendant.     15.  Upon information and belief, Defendant has sent collection letters in an attempt to collect  a debt to hundreds if not thousands of consumers throughout United States, each of which violates  the FDCPA. The members of the Class, therefore, are believed to be so numerous that joinder of  all members is impracticable.   16.  The exact number and identities of the Class members are unknown at this time and can  only be ascertained through discovery. Identification of the Class members is a matter capable of  ministerial determination from Defendants’ records.   Common Questions of Law and Fact   17.  There are questions of law and fact common to the class that predominates over any  questions affecting only individual Class members. These common questions of law and fact  include, without limitation: (i) whether Defendant violated the provision of the FDCPA; (ii)  whether the Plaintiff and the Class have been injured by the conduct of Defendant; (iii) whether  the Plaintiff and the Class have sustained damages and are entitled to restitution as a result of  Defendant’s wrongdoing and, if so, what is the proper measure and appropriate statutory formula  to be applied in determining such damages and restitution; and (iv) whether the Plaintiff and the  Class are entitled to declaratory and/or injunctive relief.  Typicality   19.  Plaintiff will fairly and adequately represent the Class members’ interests, in that the  Plaintiff's counsel is experienced and, further, anticipates no impediments in the pursuit and  maintenance of the class action as sought herein.    20.  Neither the Plaintiff nor her counsel have any interests, which might cause them not to  vigorously pursue the instant class action lawsuit.  Proceeding Via Class Action is Superior and Advisable   21.  A class action is superior to other methods for the fair and efficient adjudication of the  claims herein asserted, this being specifically envisioned by Congress as a principal means of  enforcing the FDCPA, as codified by 15 U.S.C.§ 1692(k).   22.  The members of the Class are generally unsophisticated individuals, whose rights will not  be vindicated in the absence of a class action.   23.  Prosecution of separate actions by individual members of the Class would create the risk  of inconsistent or varying adjudications resulting in the establishment of inconsistent or varying  standards for the parties.   24.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure is also   appropriate in  that  the  questions of  law  and  fact  common to  members of  the Plaintiff's Class  predominate over any questions affecting an individual member, and a class action is superior to  other available methods for the fair and efficient adjudication of the controversy.   26.  Absent a class action, the Class members will continue to suffer losses borne from the  Defendant’s breaches of Class members’ statutorily protected rights as well as monetary damages,  thus allowing and enabling: (a) Defendant’s conduct to proceed and; (b) Defendant to further enjoy  the benefit of its ill-gotten gains.   27.  Defendant has acted, and will act, on grounds generally applicable to the entire Class,  thereby making appropriate a final injunctive relief or corresponding declaratory relief with respect  to the Class as a whole.  28. Plaintiff repeats, re-alleges, and re-asserts the allegations contained in the above paragraphs  and incorporates them as if specifically set forth at length herein.   29. Defendant’s actions are in violation of 15 U.S.C. § 1692c(b).   WHEREFORE, Plaintiff, Nina Coulter, respectfully requests that this Court do the  following for the benefit of Plaintiff:  A. Certify the class described herein and appoint Plaintiff as Lead Plaintiff,  and Plaintiff’s Counsel as Lead Counsel;   B. Enter judgment against Defendant for statutory damages pursuant to the  6. On a date better known to Defendant, Plaintiff incurred a debt for personal, familial, or  household purposes.    7. The bill was handed to Defendant to collect.   8. In an attempt to collect the debt, Defendant sent Plaintiff a collection letter.    9. Upon information and belief, Defendant utilized a third-party vendor to send the letter.    The Class   VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. § 1692 et seq.  