12.  Plaintiffs bring this claim on behalf of the following class, pursuant to  Fed. R. Civ. P. 23(a) and 23(b)(3):   13.  The Class consists of (a) all individuals with addresses in the State of  California (b) to whom Defendant (c) sent an initial collection letter attempting to  collect a consumer debt (d) without clearly identifying the name of the current  creditor to whom the debt is owed (e) which letter was sent on or after a date one  year prior to the filing of this action and on or before a date 21 days after the filing  of this action.   14.  The identities of all class members are readily ascertainable from the  records of Defendants and those companies and entities on whose behalf they  attempt to collect and/or have purchased debts.   15.  Excluded from the Plaintiff Classes are the Defendants and all  officers, members, partners, managers, directors, and employees of the Defendants  and their respective immediate families, and legal counsel for all parties to this  action and all members of their immediate families.   16.  There are questions of law and fact common to the Plaintiff Classes,  which common issues predominate over any issues involving only individual class  members. The principal issue is whether the Defendants’ written communications  to consumers, in the forms attached as Exhibits A, violate 15 U.S.C. §§ 1692g.   22.  Plaintiff repeats, reiterates and incorporates the allegations contained  in paragraphs numbered above herein with the same force and effect as if the same  were set forth at length herein.   23.  Some time prior to March 14, 2017, an obligation was allegedly  incurred to Mercury Casualty Insurance.   44.  Plaintiff, individually and on behalf of all others similarly situated,  repeats, reiterates and incorporates the allegations contained in paragraphs above  herein with the same force and effect as if the same were set forth at length herein.   45.  Defendant’s 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.   46.  Pursuant to 15 U.S.C. §1692g, a debt collector is required in the initial  communication with a consumer, to identify the name of the creditor to whom the  debt is owed.   47.  The Defendant violated section 1692g(a)(2) by failing to clearly and  concisely identify the current creditor.    48.  By reason thereof, Defendant is liable to Plaintiff for judgment that  Defendant's conduct violated Section 1692g et seq. of the FDCPA, actual damages,  statutory damages, costs and attorneys’ fees.  49.  Plaintiff repeats, reiterates and incorporates the allegations contained  in paragraphs above herein with the same force and effect as if the same were set  forth at length herein.    VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692g et seq.   VIOLATIONS OF THE ROSENTHAL FAIR DEBT COLLECTION  PRACTICES ACT  Cal. Civ. Code § 1788 et seq.  