13. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered “1” through “12” herein with the same force and effect as if the same were set  forth at length herein.   14. Defendant 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.   15. Upon information and belief, within the last year the Defendant began a collection  campaign against the Plaintiff in an attempt to collect an alleged “debt” as defined by 15  U.S.C. 1692a(5).   16. On or about January 27, 2015, the Defendant sent the Plaintiff an initial collection letter.   See Exhibit A.   17. The back of Defendant’s letter to the Plaintiff (See Exhibit B) stated in part:  “Note that a $10.00 processing fee may be added to all credit card payments, if  allowed by the laws of your state.”   18. Upon information and belief, the Defendant has no legal or contractual right to charge a  processing fee.   20. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered “1” through “19” herein with the same force and effect as if the same were set  forth at length herein.   21. 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(2), 1692e(5), and 1692e(10).   22. Pursuant to 15 U.S.C. § 1692e, a debt collector may not use any false, misleading and/or  deceptive means to collect or attempt to collect any debt or to obtain information  concerning a consumer.    23. The Defendants violated said section by falsely representing the character, amount, or  legal status of the debt and falsely representing that a transaction fee may lawfully be  received by the Defendant in violation of 15 U.S.C. § 1692e(2)(A) and 1692e(2)(B).   24. The Defendant further violated said section by threatening to charge a fee that cannot  legally be charged in violation of 15 U.S.C. § 1692e(5).   25. The Defendant further violated said section by using false representation or deceptive  means in an attempt to collect the alleged debt in violation of 15 U.S.C. § 1692e(10).   27. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered “1” through “26” herein with the same force and effect as if the same were set  forth at length herein.   28. Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated 15 U.S.C. § 1692(f)1 of the FDCPA.   29. Pursuant to 15 U.S.C. § 1692(f), a debt collector may not use unfair or unconscionable  means to collect or attempt to collect any debt.   Without limiting the general application  of the foregoing, the following conduct is a violation of this section: (1) The collection of  any amount (including interest, fee, charge or expense incidental to the principal  obligation) unless such amount is expressly authorized by the agreement creating the debt  or permitted by law.   30. Defendants violated said section by stating in their November 11, 2014 letter that a fee  may be charged for payments made by phone.   31. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's conduct  violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  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. §1692e et seq.  