10.  FFIF also attempted to collect debts against numerous Arkansas residents  through dunning letters and phone calls, while it was not licensed as a debt collector with  theASBCA.   11.  Additionally, FFIF was also not a licensed debt collector with the ASBCA at  the time it filed its Complaint against Lucas.   12.  FFIF also filed debt-collection complaints against hundreds of Arkansas  residents when it was not licensed with the ASBCA. The filing of these collection lawsuits  is a collection activity under the AFDCP A.   13.  The complaints filed and served on Lucas and the Class Members in  connection and collection of a debt and in an attempt to collect a debt were all a  "communication" under Ark. Code Ann.§ 17-24-502(1).   15.  Lucas re-alleges and incorporates the foregoing paragraphs, as if set forth,  word for word.   16.  The Class is defined as:  All Arkansas residents who were subject to collection actions (including both  non-judicial and judicial methods of collection) by FFIF for collection of a  purported debt at a time FFIF was not licensed by the ASBCA.  Excluded from the Class are the judge presiding over this civil action and his/her  immediate family members, and FFIF, its members, parent, any subsidiaries,  officers, directors, agents, and employees.   17.  Lucas's claims are typical of debt collection efforts between FFIF and all  Class Members whom FFIF attempted to collect a debt from during times it was not  properly licensed to do so.   19.  These issues are common among all Class Members and predominate over  any issues affecting individual members of the Class.   20.  FFIF filed numerous of debt-collection complaints in Arkansas when it was  not licensed by the ASBCA.   21.  FFIF has made numerous non-judicial collection efforts against Arkansas  residents when it was not licensed by the ASBCA.   22.  The Class Members are so numerous and scattered throughout Arkansas that  joinder of all members is impracticable.   23.  A class action is superior to other available methods of relief for the fair and  efficient adjudication of the claims raised.   24.  Absent class action relief, the Class Members would be forced to prosecute  hundreds of similar claims in courts throughout Arkansas, which would waste the judicial  resources and risks inconsistent outcomes.   25.  The prosecution of these claims as a class action will promote judicial  economy.   26.  The claims raised are well suited for class action relief.   28.  Lucas is interested in the outcome and understands the importance of  adequately representing the Class.   29.  Lucas will fairly and adequately protect the interests of the Class sought to  be certified.   30.  Class counsel are experienced in class action and complex consumer  litigation and are required to adequately represent the Class.   31.  This case fully satisfies Ark. R. Civ. P. 23's requirements and should be  certified as a class action.  9.  Prior to filing its Complaint against Lucas in Pulaski County District Court  on October 9, 2012, FFIF made several attempts to collect the alleged debt at issue. At such  times, FFIF was not a licensed debt collector with the ASBCA during these collection  efforts. A copy of the Complaint is attached as Exhibit A.  