23.  On April 27, 2018, on behalf of Defendants, another debt collector, Frontline  Asset Strategies, sent Plaintiff a letter in an attempt to collect the Debt from Plaintiff. (A true  and exact copy of Frontline’s letter to Plaintiff ,dated April 27, 2018, is attached hereto as  Exhibit C).   24.  The aforesaid letter was the initial communication with Plaintiff.   26.  Plaintiff received Defendants April 27, 2018 letter on May 11, 2018, and on June  5, 2018 sent a letter to Frontline disputing the Debt and requesting validation. (A true and exact  copy of said correspondence sent by Plaintiff to Frontline, with a certified mail receipt and  UPS.com tracking printout, is attached hereto as Group Exhibit D).   27.  On June 7, 2018, Frontline received the aforesaid correspondence sent by  Plaintiff, see, Group Exhibit D.   28.  Frontline forwarded Plaintiff’s dispute to Defendants.   29.  Without providing validation, on June 18, 2018, Defendants sent Plaintiff a letter  in an attempt to collect the Debt.  (A true and exact copy of Resurgent’s correspondence to  Plaintiff, dated June 18, 2018 is attached hereto as Exhibit E).   30.  In the letter sent by Defendants to Plaintiff, dated June 18, 2018, Resurgent stated,  inter alia, “Resurgent Capital Services L.P. manages the above referenced account for LVNV  Funding LLC and has initiated a review of the inquiry we recently received.”   36.  This action seeks a finding that Defendant’s form letter violates the FDCPA, and  asks that the Court award damages as authorized by § 1692k(a)(2) of the FDCPA.   37.  The class is so numerous that joinder of members is impracticable.   38.   The exact number of class members is unknown to Plaintiff at this time but can  be easily ascertained through appropriate discovery.   39.  The class is ascertainable in that the names and addresses of all class members  can be identified in business records maintained by Defendants.    40.  There exists a well-defined community of interest in the questions of law and fact  involved that affect the parties to be represented. These common questions of law and fact  predominate over questions that may affect individual class members. Such issues include, but  are not limited to:  a. The existence of Defendants’ identical conduct particular to the matters at  issue;  b. Defendants’ violations of the federal Fair Debt Collection Practices Act;  c. The availability of statutory penalties; and,  d. The availability of attorneys’ fees and costs.   41.  The claims of Plaintiff are typical of those of the class she seeks to represent.   42.  The claims of Plaintiff and of the class originate from the same conduct, practice,  and procedure, on the part of Defendants. Thus, if brought and prosecuted individually, the  claims of each class members would require proof of the same material and substantive facts.   44.  Plaintiff asserts identical claims and seeks identical relief on behalf of the  unnamed class members.    45.  Plaintiff will fairly and adequately protect the interests of the class and has no  interest adverse to or which directly and irrevocably conflicts with the interests of other  members of the class.   46.  Plaintiff is willing and prepared to serve this Court and proposed class.   47.  The interests of Plaintiff are co-extensive with and not antagonistic to those of the  absent class members.   48.  Plaintiff has retained the services of counsel who are experienced in consumer  protection claims, as well as class action litigation, will adequately prosecute this action, and  will assert, protect and otherwise represent Plaintiff and all absent class members.   49.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(1)(A) and  23(b)(1)B). The prosecution of separate actions by individual members of the class would, as a  practical matter, be dispositive of the interests of other members of the class who are not parties  to the action or could substantially impair or impede their ability to protect their interests.    51.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(3) in that the  questions of law and fact that are common to members of the class predominate over any  questions affecting only individual members.   52.  Moreover, a class action is superior to other methods for the fair and efficient  adjudication of the controversies raised in Plaintiff’s Complaint in that:  a. Individual claims by the class members will be impracticable as the costs of  pursuit would far exceed what any one plaintiff or class member has at stake;  b. As a result, very little litigation has been commenced over the controversies  alleged in Plaintiff’s Complaint and individual members are unlikely to have  interest in prosecuting and controlling separate individual actions; and,  c. The concentration of litigation of these claims in one forum will achieve  efficiency and promote judicial economy.   WHEREFORE, Plaintiff, Yvonne Mack, individually and on behalf of all others similarly  situated, prays for judgment as follows:  a. Certify the class in this matter, appoint Plaintiff as class representative and her   attorneys as class counsel;  b. Finding that Defendants violated the Fair Debt Collection Practices Act;  c. Enter judgment in favor of Plaintiff Mack and the Class, and against  Defendants, for statutory damages, costs, and reasonable attorneys’ fees as  provided by § 1692k(a) of the FDCPA; and,   d. Awarding Plaintiff, and all others similarly situated, any other relief deemed  appropriate by this Honorable Court. 