1.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   10.  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.   12.  The Capital One Bank (USA) N.A. obligation arose out of transactions in which  money, property, insurance or services, which are the subject of the transaction, were primarily  for personal, family or household purposes.   13.  The alleged Capital One Bank (USA) N.A. obligation is a "debt" as defined by 15  U.S.C.§ 1692a(5).   14.  Defendant PRA, contracted with the Capital One Bank (USA) N.A. to collect the  alleged debt.   15.  Defendant PRA collects and attempts to collect debts incurred or alleged to have  been incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and internet.  Violation – February 20, 2020 Collection Letter   16.  On or about February 20, 2020, Defendant PRA sent Plaintiff an initial collection  letter (the “Letter”) regarding the alleged debt owed to Capital One Bank (USA) N.A. See  Exhibit A.   17.  The Letter states a balance of $1000.10.   18.  The Letter offers two options regarding the balance: Either pay the full amount or  select a “savings plan” that allows the consumer to pay the balance for a discounted amount.   19.  Below the offer to pay in full, the letter states: “Your Account will be considered  paid-in-full after your final payment is successfully posted.”   2.  The Class consists of:   a. all individuals with addresses in the State of Minnesota;  b. to whom Defendant PRA sent a collection letter attempting to collect a consumer  debt;  c. that included materially misleading and deceptive language regarding whether  the account would be considered paid-in-full or considered paid-in-full for less  than the full balance after final payment is made;  d. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (2l) days after the filing of this action.   21.  Below both offers, the Letter includes a sentence that states: “Within approximately  30 days of your final payment successfully posting, we will request that the three major credit  reporting agencies delete our tradeline related to your account from your credit bureau report.”   22.  The statement that Defendant will request deletion from the credit bureaus upon final  payment is not qualified in any way and the plain reading implies that these deletion will take  place in both scenarios; whether the balance is paid in full or paid for less than the full balance.   23.  Upon Defendant’s request to delete the tradeline from the credit bureaus upon final  payment, the account will no longer appear on the credit report of the Plaintiff in any form.   24.  Therefore, there is no consequence to Defendant’s earlier statements in the Letter  that the account will be “considered” paid in full or “paid in full for less than the full balance,”  because in either scenario, the account will simply not appear on Plaintiff’s credit report.   25.  The earlier statements are deceptive and misleading, because they propose to offer a  benefit of considering the account “paid-in-full,” which essentially does not exist, because the  account will be deleted entirely upon final payment.   26.  Just the fact that letter at all states that there is a status for each type of payment  option is misleading, when in fact either option results in a complete wiping away of the account  having existed at all.   27.  In the alternative, if Defendant’s statement that they will request a deletion of  tradeline is hinged upon selection of only one of the payment options, then the Letter is unclear  and misleading for not properly elucidating that fact.    29.  As a result of Defendant deceptive, misleading and unfair debt collection practices,  Plaintiff has been damaged.  3.  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.   30.  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.   31.  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.   32.  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.   33.  Defendants violated §1692e:   a. By making a false and misleading representation in violation of §1692e(10).   34.  By reason thereof, Defendants are liable to Plaintiff for judgment that Defendants  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  4.  Excluded from the Plaintiff Class are the Defendants and all officer, 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.    6.  The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiff will fairly and adequately protect the interests of the  Plaintiff Class defined in this complaint. The Plaintiff has retained counsel with experience in  handling consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiff  nor her attorneys have any interests, which might cause them not to vigorously pursue this  action.   8.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Class predominate over any questions affecting an individual member, and a class action is  superior to other available methods for the fair and efficient adjudication of the controversy.   9.  Depending on the outcome of further investigation and discovery, Plaintiff may, at  the time of class certification motion, seek to certify a class(es) only as to particular issues  pursuant to Fed. R. Civ. P. 23(c)(4).  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  