10.  Defendant alleges Plaintiff owes a debt (“the Debt”).     11.  The Debt was primarily for personal, family or household purposes and is  therefore a “debt” as defined by 15 U.S.C. § 1692a(5).   12.  Sometime after the incurrence of the Debt, Plaintiff fell behind on payments  owed.    13.  Thereafter, at an exact time known only to Defendant, the Debt was assigned or  otherwise transferred to Defendant for collection.    14.  In its efforts to collect the debt, Defendant contacted Plaintiff by letter (“the  Letter”) dated August 11, 2017. (“Exhibit 1.”)    15.  The Letter was the initial communication Plaintiff received from Defendant.   16.  The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).   17.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     18.  Pursuant to the terms and conditions of the account, Plaintiff was charged fees on  any payments due but not timely made by Plaintiff.   26.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     27.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.   28.  15 U.S.C. § 1692g(a)(1) requires the written notice provide “the amount of the  debt.”   29.  The written notice, to comply with 15 U.S.C. § 1692g(a)(1), must convey the  amount of the debt clearly from the perspective of the least sophisticated consumer.   30.  The written notice, to comply with 15 U.S.C. § 1692g(a)(1), must convey the  amount of the debt accurately from the perspective of the least sophisticated consumer.   31.  The written notice, to comply with 15 U.S.C. § 1692g(a)(1), must convey the  amount of the debt without ambiguity from the perspective of the least sophisticated consumer.   57.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     58.  As previously set forth, Plaintiff was always charged fees on any payments due  but not timely made by Plaintiff.   59.  As previously set forth, Plaintiff was never informed by anyone that the terms and  conditions of the account were changed.   60.  The Letter fails to disclose whether the amount stated may increase due to  additional fees.   70.  Plaintiff brings this action individually and as a class action on behalf of all  persons similarly situated in the State of Florida from whom Defendant attempted to collect a  consumer debt using a collection letter with the same deficiencies as the Letter herein, from one  year before the date of this Complaint to the present.    71.  This action seeks a finding that Defendant’s conduct violates the FDCPA, and  asks that the Court award damages as authorized by 15 U.S.C. § 1692k.   72.  Defendant regularly engages in debt collection.   Violation of 15 U.S.C. § 1692e   Violation of 15 U.S.C. § 1692e   Violation of 15 U.S.C. § 1692g  