11.  Defendants allege Plaintiff owes a debt (“the Debt”).     12.  The Debt was primarily for personal, family or household purposes and is  therefore a “debt” as defined by 15 U.S.C. § 1692a(5).   13.  Sometime after the incurrence of the Debt Plaintiff fell behind on payments owed.    14.  Thereafter, at an exact time known only to Defendants, the debt was assigned or  otherwise transferred to Defendants for collection.    15.  In their efforts to collect the debt, Defendants contacted Plaintiff by letter (“the  Letter”) dated June 16, 2017. (“Exhibit 1.”)    16.  The letter is a “communication” as defined by 15 U.S.C. § 1692a(2).  17.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     18.  The Debt was incurred on a credit card underwritten by WebBank.    19.  The Letter sets forth a “Principal Amount Due” of $23,410.98.   20.  The Letter sets forth “Interest Due” of $1,879.39.  3  47.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.    5  83.  Plaintiff brings this action individually and as a class action on behalf of all  persons similarly situated in the State of New York from whom Defendants attempted to collect a  consumer debt using a substantially similar form collection letter, from one year before the date  of this Complaint to the present.    84.  This action seeks a finding that Defendants’ conduct violates the FDCPA, and  asks that the Court award damages as authorized by 15 U.S.C. § 1692k.   85.  Defendants regularly engage in debt collection.   86.  The Class consists of more than 35 persons from whom Defendants attempted to  collect delinquent consumer debts using a substantially similar form collection letter.   87.  Plaintiff’s claims are typical of the claims of the Class.  Common questions of law  or fact raised by this class action complaint affect all members of the Class and predominate over  any individual issues. Common relief is therefore sought on behalf of all members of the Class.  This class action is superior to other available methods for the fair and efficient adjudication of  this controversy.   88.  The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of  the Class, and a risk that any adjudications with respect to individual members of the Class  would, as a practical matter, either be dispositive of the interests of other members of the Class  not party to the adjudication, or substantially impair or impede their ability to protect their  8  Violation of 15 U.S.C. § 1692e   Violation of 15 U.S.C. § 1692e  