1.1(d).   10.  The alleged debt is a “debt” as defined by 15 U.S.C. §1692a(5) and 23 NYCRR §   12.  Within the one (1) year preceding the filing of this complaint, Defendant  communicated and/or attempted to communicate with Plaintiff in an attempt to collect the  alleged debt.   13.  On or about May 20, 2015, Defendant mailed or caused to be mailed to Plaintiff a  collection or “dunning” letter via U.S. Mail in an attempt to collect the alleged debt from  Plaintiff (“letter”). The letter is attached to this complaint as Exhibit A.   14.  Collection/“dunning” letters in the year prior to the filing of the instant action  between the Plaintiff and the Defendant and / or employee(s) of the Defendant regarding the  alleged debt each constituted a “communication” as defined by FDCPA § 1692a(2).   15.  Collection/“dunning” letters in the year prior to the filing of the instant action  between the Plaintiff and the Defendant and / or employee(s) of the Defendant regarding the  alleged debt each conveyed information regarding the alleged debt directly or indirectly to the  Plaintiff.   16.  Defendant’s letter is a form letter that Defendant directs at hundreds, if not  thousands of consumers within the State of New York.   17.  Defendant’s letter states, in relevant part:  52.  Plaintiff brings this claim on behalf of a class pursuant to Fed.R.Civ.P.  23(a) and 23(b)(3).   53.  The class consists of all individuals in Michigan to whom Northland  Group, Inc. sent a letter seeking to collect a debt, which debt was a consumer debt on which the  last payment had been made more than six years prior to the letter, and which letter was sent on  or after a date one year prior to the filing of this action and on or before a date 20 days after the  filing of this action.   54.  On information and belief, the class is so numerous that joinder of all members is  not practicable.   56.  Plaintiff’s claim is typical of the claims of the class members. All are based on the  same factual and legal theories.   57.  Plaintiff will fairly and adequately represent the class members. Plaintiff has  retained counsel experienced in class actions and FDCPA litigation.   58.  A class action is superior for the fair and efficient adjudication of this matter, in  that:  a. Individual actions are not economically feasible,  b. Members of the class are likely to be unaware of their rights, and  c. Congress intended class actions to be the principal enforcement mechanism  under the FDCPA.  8.  Plaintiff repeats, reiterates and incorporates the allegations contained in  paragraphs numbered “1” through “7” herein with the same force and effect as if the same were  set forth at length herein.   9.  On information and belief, Defendant, on behalf of LVNV Funding, LLC, began  collecting an alleged consumer debt from the Plaintiff originating with Capital One Bank (USA),  N.A. (“the alleged debt”).   Current Creditor: LVNV Funding, LLC  Original Creditor: Capital One Bank (USA), N.A.  Original Account #: ***********1400  Current Balance Due: $1,418.99 