              PRACTICES ACT   10.   Plaintiff is a user of  telephone services for her personal use and a   "consumer" as that term is defined by §1692a(3) of the FDCPA.   11.   Plaintiff incurred an alleged debt for goods and services for personal,   family or household purposes, with regards to a cellular phone account with   T-Mobile (“alleged debt” herein).    12.   The alleged debt is a “debt” as that term is defined by §1692a(5) of the   FDCPA, i.e. – telephone services for personal use.         13.   Due to her financial circumstances, Plaintiff could not pay the alleged  debt, and it subsequently went into default.   14.  Plaintiff has information and belief that the last payment on the alleged  debt was prior to January 1, 2016.   15.   The alleged debt was subsequently assigned to Southwest Credit   for the purposes of collecting the alleged debt.   18.  The language of the Letter further indicated that the Letter was also a  solicitation to resolve the alleged debt for a discount. The Letter also created a  false sense of urgency by stating that “we are not obligated to renew this offer”.   19.  The Letter further indicated an account balance of $1978.01.    20.  However, Defendants’ records and/or the records of T-Mobile show   Plaintiff’s last payment was made on her account at least four or more years before  the date of the Letter, February 27, 2020.      22.  The Letter which sought to collect a time barred alleged debt was false   and misleading to the unsophisticated/least sophisticated consumer in so much as  at the very least it failed to disclose in any way that a) the alleged debt was time  barred debt and unenforceable, and b) that any partial payment could reinstate the  applicable statute of limitations. See Daugherty v. Convergent Outsourcing, Inc.,  836 F.3d 507 (5th Cir. 2016).             23.  The Letter was a "communication" as that term is defined in 15 U.S.C.  §1692a(2).    24.  Plaintiff alleges that Defendants, John Does, approved, directed, and/or   supervised the preparation and sending of letters in the form of Exhibit A to Ms.  Traylor and the class members.   25.  Plaintiff further alleges that Exhibit A was misleading and created a   significant risk of harm as contemplated by the FDCPA and constitutes a concrete  injury in-fact as articulated in Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 1549  (2016).   27.  Plaintiff re-alleges the above paragraphs as if set forth fully in this  count.   28.  15 U.S.C. §1692e(2)(A) and (10) of the FDCPA provide as follows:  30.  Plaintiff re-alleges the above paragraphs as if set forth fully in this  count.   31.  15 U.S.C. §1692f of the FDCPA provides as follows:   PRACTICES ACT  