12.  Each of the specific acts alleged in this Complaint are alleged to be  consistent with Defendants’ abusive, unfair, unconscionable, and unlawful practices,  which were designed to or had the natural consequence of attempting to improperly obtain  money from consumers for the Defendants’ economic benefit and to the detriment of both  consumers and law abiding debt collectors.   53.  DIEUVEILLE repeats the foregoing factual allegations by reference.   54.  The alleged Obligation is a “debt” as defined by 15 U.S.C. § 1692a(5).   55.  DIEUVEILLE is a “consumer” as defined by 15 U.S.C. § 1692a(3).   56.  C-SPV is a “debt collector” as defined by 15 U.S.C. § 1692a(6).   57.  CPS is a “debt collector” as defined by 15 U.S.C. § 1692a(6).   58.  ASPC is a “debt collector” as defined by 15 U.S.C. § 1692a(6).   59.  SCIAN is a “debt collector” as defined by 15 U.S.C. § 1692a(6).   60.  The Defendants violated the FDCPA.   63.  Based on any one of those violations, Defendants are liable to  DIEUVEILLE for statutory damages, attorney’s fees and costs under 15 U.S.C. § 1692k   64.  As a direct, proximate, and legal cause of the Defendants’ violations of the  FDCPA, DIEUVEILLE has suffered actual damages.  PRACTICES ACT AGAINST ALL DEFENDANTS  