13.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   15.  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.   16.  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.    17.  There are questions of law and fact common to the Plaintiff Class, 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  Exhibit A, violate 15 U.S.C. §§ l692e, 1692g.   20.  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.   21.  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).  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 April 27, 2020, an obligation was allegedly incurred to Capital  One Bank (USA), N.A. by the Plaintiff.   24.  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 transactions were primarily  for personal, family or household purposes.   26.  Capital One Bank (USA), N.A. is a “creditor” as defined by 15 U.S.C. §1692a(4).   27.  Defendant MCM, a debt collector, purportedly purchased the Capital One Bank  (USA), N.A. debt and the debt has now been placed with Defendant PFW for collections.    28.  Defendants collect and attempt 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 I – April 27, 2020 Collection Letter   29.  On or about April 27, 2020, Defendant PFW sent Plaintiff a collection letter (the  “Letter”) regarding the alleged debt currently owed to Capital One Bank (USA), N.A. See  Exhibit A.   30.  This letter did not contain all the requirements of the ‘‘G Notice.'' Specifically, this  letter deceptively fails to identify who the current creditor is to whom the alleged debt is owed.   31.  The letter only states: “This is to notify you that on 8/29/2019 Midland Credit  Management, Inc. purchased your Capital One Bank (USA), N.A., account number xxxx, which  has now been placed with Pressler, Felt & Warshaw, LLP for collection.   32.   Nowhere does the letter clearly identify who the current creditor is as is required by  the FDCPA.   33.  The least sophisticated consumer cannot decipher from the body of the letter whom  the current creditor is because it is not stated clearly.   35.  It is deceptive to not clearly state who the creditor is in any collection letter sent to a  consumer.   36.  Mere illusions are not enough, but the letter must specifically and clearly state who  the creditor is.   37.  Defendant has failed to provide the consumer with a proper initial communication  letter by failing to clearly identify the original and current creditors of the debt.   38.  As a result of Defendant’s deceptive misleading and false debt collection practices,  Plaintiff has been damaged  39.  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.   40.  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. § 1692e.   41.  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.   42.  Defendant violated said section by:   a. Making a false and misleading representation in violation of §1692e(10).   44.  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.   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 must notify the consumer of the name  of the creditor to whom the debt is owed. §1692g(a)(2).   47.  This notice must be clearly conveyed so that the consumer is clearly advised as to  whom the alleged debt is owed.   48.  Defendant violated this section by unfairly failing to advise Plaintiff as to the identity  of the current creditor who was attempting to collect a debt from her.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C.  §1692g et seq.  