1. The amount of the debt…   11.  Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   12.  The Class consists of:   a. all individuals with addresses in the State of Tennessee;  b. to whom Defendant ProCollect sent an initial letter;   c. attempting to collect a consumer debt;  d. claiming that the listed balance may be inaccurate or may increase;  e. without providing the amount of such inaccuracy or increase or a way to calculate  it;  f. 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 (21) days after the filing of this action.   14.  Excluded from the Plaintiff Class are the Defendant and all officers, members,  partners, managers, directors and employees of the Defendant and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate families.    15.  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 Defendant’s written communications to consumers, in the form attached as Exhibit A,  violate 15 U.S.C. §§ 1692e, 1692f, and 1692g.   16.  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 counsel  have any interests which might cause them not to vigorously pursue this action.   18.  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.   19.  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).  20.  Plaintiff repeats the allegations above as if set forth here.   21.  On a date better known to Defendant, Plaintiff allegedly incurred a debt to non-party  Centennial Gardens Apartments.   22.  This alleged debt was incurred as a financial obligation that was primarily for  personal, family or household purposes and is therefore a “debt” as that term is defined by 15 U.S.C.  § 1692a (5), specifically a personal apartment rental.   23.  Centennial Gardens Apartments is a “creditor” as defined by 15 U.S.C. §1692a (4).   24.  Upon information and belief, Centennial Gardens Apartments then contracted with  Defendant ProCollect to collect this alleged debt.   25.  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.  Violation – the April 21, 2020 Letter   26.  On or around April 21, 2020, Defendant sent the Plaintiff an initial collection letter.  A true and accurate copy of this letter from Defendant is attached as Exhibit A.    27.  The letter lists the amount due as $233.39*.   28.  Towards the bottom of the letter its states:  *Your agreement with the original creditor, or other applicable state law, may  allow ProCollect to charge collection agency fees. If you have not already  been put on notice of any applicable fee, this is your notice that a failure to  pay the Amount Due within the applicable deadline set out in the agreement  with the original creditor or state law, may result in ProCollect assessing  collection agency fees allowed by such agreement or state law.   29.  No amounts are listed for these “collection agency fees”.    31.  No deadline is given for when these fees might be assessed.   32.  The consumer is therefore unable to determine the actual total balance due.   33.  This letter lacks the proper notice required by 15 U.S.C. § 1692g.   34.  In addition, upon information and belief, Defendant does not intend to collect  “collection agency fees”.   35.  The mention of these fees is just a scare tactic and misleads the consumer into paying  the alleged debt.   36.  As a result of Defendant's false and unfair debt collection practices, Plaintiff has been  damaged.  37.  Plaintiff repeats the allegations above as if set forth here.   38.  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.   39.  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.   41.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs and  attorneys’ fees.  42.  Plaintiff repeats the allegations above as if set forth here.   43.  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. § 1692f.   44.  Pursuant to 15 U.S.C. §1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.   45.  Defendant violated this section by failing to state the amount of debt and threatening  that the amount of the debt may increase even though it would not actually increase.   46.  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.  47.  Plaintiff repeats the allegations above as if set forth here.   48.  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.   50.  Defendant violated 15 U.S.C. § 1692g by:  a. Failing to provide the actual amount of the debt.   51.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692g 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. §1692g et seq.   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.  