14.  On or about July 2, 2014, First Step mailed a debt collection letter to Plaintiff  regarding an alleged debt. A copy of this letter is attached to this complaint as Exhibit A.   15.  Upon information and belief, the alleged debt referred to in Exhibit A was alleged  personal, “CareCredit” branded credit card account, originally with GE Capital Retail Bank,  N.A. (GE Capital) and only used for personal, family or household purposes.   16.  Upon information and belief, Exhibit A was the first letter that First Step sent to  Plaintiff regarding the alleged debt referenced in the letter.   17.  Upon information and belief, Exhibit A is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.   18.  Exhibit A identifies the creditor as “CACH, LLC.”   19.  CACH, LLC acquired the account identified in Exhibit A after it was in default.   20.  Exhibit A tells the consumer that the “Original Creditor” is “SYNCHRONY  41.  Plaintiff incorporates by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   42.  Exhibit A identifies the original creditor as “SYNCHRONY LENDING, INC.”   43.  “SYNCHRONY LENDING, INC.” is not the name of any past or present  creditor.   44.  Exhibit B identifies the original creditor as “SYNCHRONY BANK.”   45.  The language in First Step’s letters is false, misleading and confusing to the  unsophisticated consumer, in that one of the letters (Exhibit A) incorrectly states the name of the  original creditor, the other uses a name that was never used during the pendency of the Plaintiff’s  credit relationship, and both together are confusing as to the identity of the original creditor.    47.  Plaintiff brings this action on behalf of a Class, consisting of (a) all natural  persons in the State of Wisconsin (b) to whom First Step Group, LLC sent a collection letter  seeking to collect a debt allegedly owed to CACH, LLC (c) which letter stated that the original  creditor is “SYNCHRONY LENDING, INC.” or “SYNCHRONY BANK”, (d) seeking to collect  a debt for personal, family or household purposes, (e) between the dates of July 2, 2014, and  September 30, 2014 (f) that was not returned by the postal service.   48.  The Class is so numerous that joinder is impracticable.  On information and  belief, there are more than 50 members of the Class.   49.  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 Defendants complied with 15 U.S.C. § 1692e.   50.  Plaintiff’s claims are typical of the claims of the Class members.  All are based on  the same factual and legal theories.   51.  Plaintiff will fairly and adequately represent the interests of the Class members.  Plaintiff has retained counsel experienced in consumer credit and debt collection abuse cases.   52.  A class action is superior to other alternative methods of adjudicating this dispute.    Individual cases are not economically feasible.  Defendants.  ) )  )  )  )  )  )  )  )  )  ) Case No.: 14-cv-1425 