1. The amount of the debt; …   14. Defendants have been attempting to collect from plaintiff an alleged credit card  debt, incurred (if at all) for personal, family or household purposes and not for business purposes.   15. On or about January 2, 2020, defendant UCB, acting on behalf of defendant  LVNV, sent plaintiff the letter attached as Exhibit A.   16. Exhibit A is the first letter plaintiff received from defendant UCB regarding the  alleged debt described therein.    17. Exhibit A is a form letter, filled out by computer in a standardized manner.   18. On information and belief, based on its contents, Exhibit A is a form intended for  use as the first letter defendant UCB sends to a consumer regarding the debt described therein.   19. Exhibit A contains a breakdown of the balance as follows:  4   20. Defendant’s breakdown inexplicably contains a negative amount for the total amount of  interest ‘accrued’ since charge off, without any explanation as to how this amount can be a  negative amount since the overall balance remains static once the original creditor has  charged-off the account.    21. Plaintiff was not provided with a clear accounting of the balance owed as required by the  FDCPA and was unable to evaluate how much the actual debt being collected is for or how it  has changed.   22. In addition, Exhibit A does not explain whether the negative interest amount is continuing and  if the balance would continue to decrease.    23. The language of Exhibit A is false and deceptive as Plaintiff is unable to determine if the  current balance is static or if it would continue to decrease.    24. Plaintiff was apprehensive to exercise his statutory right to dispute the debt due to the  confusing and misleading initial collection letter he received.   25. As a result of Defendant’s deceptive, misleading and unfair debt collection practices, Plaintiff  has been damaged.   26. Plaintiff repeats the above allegations as if set forth here.   27. Defendants’ 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.  5   28. 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.   29. Defendants violated said section by:   a) Making a false and misleading representation in violation of §1692e (10) by  providing inaccurate amounts for the alleged debt;  b) Falsely representing the character, amount or legal status of the debt in violation  of §1692e (2).   30. By reason thereof, Defendants are liable to Plaintiff for judgment that Defendants’ conduct  violated Section 1692e, et seq. of the FDCPA and Plaintiff is entitled to actual damages,  statutory damages, costs and attorneys’ fees.  31. Plaintiff repeats the above allegations as if set forth here.   32. Defendants’ 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.   33. 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.   34. Defendants violated this section by:   a) unfairly inserting a negative interest amount without providing an explanation of  the claimed change to the original amount of the debt;  b) by adding interest amounts to the original amount of the debt that are not  permitted by contract or law and that were in fact later removed.   6   35. By reason thereof, Defendant are liable to Plaintiff for judgment that Defendants’ conduct  violated Section 1692f, et seq. of the FDCPA and Plaintiff is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  36. Plaintiff repeats the above allegations as if set forth here.   37. Defendants’ 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. § 1692g.   38. Pursuant to 15 USC §1692g:  Within five days after the initial communication with a consumer in connection  with the collection of any debt, a debt collector shall, unless the following  information is contained in the initial communication or the consumer has paid  the debt, send the consumer a written notice containing –   39. Defendants violated 15 U.S.C. §1692g (a)(1) by failing to clearly identify the amount of the  debt.   40. By reason thereof, Defendants are liable to Plaintiff for judgment that Defendants’ conduct  violated Section 1692g et seq. of the FDCPA, and Plaintiff is entitled to actual damages,  statutory damages, costs and attorneys’ fees.  41. Plaintiff brings this claim on behalf of the following class, pursuant to Fed.R.Civ.P. 23(a) and  23(b)(3).    42. The class consists of (a) all individuals (b) with New York addresses, (c) to whom defendant  UCB sent an initial letter in the form represented by Exhibit A (d) on behalf of defendant LVNV,  7  (e) where the amount listed for the debt as of the date of the letter does not equal the amount  listed for the debt as of charge off and where the letter deceptively states a negative interest  charge with no explanation, (f) which letter was sent any time during a period beginning one  year prior to the filing of this action and ending 21 days after the filing of this action.    43. On information and belief, based on defendants’’ size and the use of a form letter, the class is so  numerous that joinder of all members is not practicable.    44. There are questions of law and fact common to the class members, which common questions  predominate over any questions relating to individual class members. The predominant common  question is whether Exhibit A violates the FDCPA.    45. Plaintiff’s claim is typical of the claims of the class members. All are based on the same factual  and legal theories.    46. Plaintiff will fairly and adequately represent the class members. Plaintiff has retained counsel  experienced in class actions and FDCPA litigation.    47. A class action is superior for the fair and efficient adjudication of this matter, in that:  a. Individual actions are not economically feasible.   b. Members of the class are likely to be unaware of their rights;  c. Congress intended class actions to be the principal enforcement mechanism under the  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e et seq.   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. §1692g et seq.  