10.  Upon information and belief, Exhibit A is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.   11.  Exhibit A contains the following text:  Exhibit A.   12.  Exhibit A falsely states that the settlement payment “must be received on or  before 08/29/13.”   14.  Statements such as a settlement offer is a “limited time offer,” or that the offer  expires on a specific date, or that payments must be received before that date, are false and  misleading because the same offer is, upon information and belief, available at any time.   15.  Such false statements are material false statements, as they impart in the  unsophisticated consumer, a false belief that he or she must hurry to take advantage of a limited- time opportunity, when in reality, there is no such time limit.   16.  The Seventh Circuit has established “safe harbor” language regarding settlement  offers in collection letters:  As in previous cases in which we have created safe-harbor language for  use in cases under the Fair Debt Collection Practices Act, we think the  present concern can be adequately addressed yet the unsophisticated  consumer still be protected against receiving a false impression of his  options by the debt collector's including with the offer the following  language: "We are not obligated to renew this offer." The word  "obligated" is strong and even the unsophisticated consumer will realize  that there is a renewal possibility but that it is not assured.  Evory v. RJM Acquisitions Funding L.L.C., 505 F.3d 769, 775-76 (7th Cir. 2007).    17.  Defendant did not use the safe harbor language in Exhibit A.   18.  Upon information and belief, the thirty day deadline to respond to the settlement  offer is a sham. There is no actual deadline. The sole purpose of the purported deadline is to  impart in the consumer a false sense of urgency.  19.  Plaintiff incorporates by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   21.  Upon information and belief, the creditor and/or DRS would settle Plaintiff’s and  class members’ debts at the offered discount and likely for less at any time, regardless of the  supposed deadline.   22.  15 U.S.C. § 1692e(10) specifically prohibits the “use of any false representation  or deceptive means to collect or attempt to collect any debt.”   23.  15 U.S.C. § 1692f generally prohibits “unfair or unconscionable means to collect  or attempt to collect any debt.”   24.  DRS violated 15 U.S.C. §§ 1692e, 1692e(10) and 1692f.  25.  Plaintiff brings this action on behalf of a Class, consisting of (a) all natural  persons in the State of Wisconsin (b) who were sent a collection letter in the form represented by  Exhibit A, (c) seeking to collect a debt for personal, family or household purposes, (d) on or after  September 27, 2012, (e) that was not returned by the postal service.   26.  The Class is so numerous that joinder is impracticable.  On information and  belief, there are more than 50 members of the Class.   27.  There are questions of law and fact common to the members of the class, which  common questions predominate over any questions that affect only individual class members.   The predominant common question is whether the Defendant complied with 15 U.S.C. §§ 1692e  and 1692f.   28.  Plaintiff’s claims are typical of the claims of the Class members.  All are based on  the same factual and legal theories.   30.  A class action is superior to other alternative methods of adjudicating this dispute.    Individual cases are not economically feasible.  8.  On or around August 13, 2013, DRS mailed a debt collection letter to Plaintiff  regarding an alleged debt, allegedly owed to “US CELLULAR”. A copy of this letter is attached  to this complaint as Exhibit A.   9.  The alleged debt identified in Exhibit A was an alleged cellular telephone service  account, allegedly owed to US Cellular and used only for personal, family or household  purposes.  