11.  Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   13.  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.   14.  Excluded from the Plaintiff Classes are the Defendants and all officer, members,  partners, managers, directors and employees of the Defendants and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate  families.    15.  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 communication to consumers, in the form attached as Exhibits  A, violate 15 U.S.C. §§ l692e, 1692f.   16.  The Plaintiffs' claims are typical of the class members, as all are based upon the same  facts and legal theories. 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 his attorneys have any interests, which might cause them not to vigorously pursue this action.   19.  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).  20.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   21.  Some time prior to December 8, 2019, an obligation was allegedly incurred to Aurora  Advanced Healthcare Inc.   22.  The Aurora Advanced Healthcare Inc. obligation arose out of transactions in which  money, property, insurance or services, which are the subject of the transaction, are primarily  for personal, family or household purposes, specifically medical purposes.   23.  The alleged Aurora Advanced Healthcare Inc. obligation is a "debt" as defined by 15  U.S.C.§ 1692a(5).   24.  Aurora Advanced Healthcare Inc. is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   25.  Defendant SCS, a debt collector, was contracted by Aurora Advanced Healthcare  and is collecting the alleged debt.   27.  On or about December 8, 2019, Defendant SCS sent the Plaintiff a debt collection  letter (the “Letter”) regarding the alleged debt owed to Defendant Aurora Advanced Healthcare  Inc. See Exhibit A.   28.  The Letter states: “If requested, this office will notify you if and when it intends to  report this claim to a credit bureau, but in no event will that happen until after the 30-day  validation period described below.”   29.  Upon information and belief, the Defendant knows which accounts are eligible to be  reported and can let the Plaintiff know in their Letter if and when the account is being reported.   30.  Instead, the Defendant seeks to lure the Plaintiff into a phone call by not providing  information they already know regarding credit.   31.  Furthermore, the Defendant fails to explain in what method the Plaintiff can invoke  the rights being offered. It is unclear if the Plaintiff must call, write, or even what to say to  invoke the above stated offer.   32.  It is deceptive to withhold information in a deceptive manner to try to get a consumer  to call a debt collector.   33.  Plaintiff incurred an informational injury due to Defendant’s deceptive statements in  the letter attempting to lure Plaintiff into contacting them through deceptive means.   34.  The Plaintiff wanted to invoke this right but had no knowledge as to how it would  occur.   36.  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.   37.  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.   38.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   39.  Defendant violated said section by making a false and misleading representation in  violation of §1692e(10).   40.  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.  41.  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.   42.  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. § 1692f.   43.  Pursuant to 15 U.S.C. §1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.   45.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692f 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.  §1692f et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  