17. At all times relevant, Plaintiffs are individuals residing within City of  Redwood City, County of San Mateo, in the State of California.   18. Plaintiffs are informed and believe, and thereon allege, that at all times  relevant, Defendant conducted business in the State of California.   19. Plaintiff are informed and believe, and thereon allege that sometime before  July 15, 2015, Plaintiffs allegedly incurred financial obligations to an original  creditor, Franklin Credit Management Corporation, that were money,  property, or their equivalent, which is due or owing, or alleged to be due or  owing, from a natural person to another person and were therefore “debt(s)”  as that term is defined by California Civil Code §1788.2(d), and a “consumer  debt” as that term is defined by California Civil Code §1788.2(f) and 15  U.S.C. § 1692a(5).   20. Sometime thereafter, Defendant alleges that Plaintiff allegedly fell behind on  the payments allegedly owed on the alleged debt. Plaintiff currently takes no  position as to the validity of the alleged debt.    21. Subsequently, the alleged debt was allegedly assigned, placed, or otherwise  transferred, to Defendant for collection activity.    22. On or about July 16, 2015, Defendant sent Plaintiff an initial written  communication in regards to the alleged debt in an attempt to collected the  alleged past due amount (the “Letter”). This Letter is considered a  “communication” as 15 U.S.C. § 1692a(2) defines that term, and “debt  collection” as that phrase is defined by Cal. Civ. Code § 1788.2(b).   51. Plaintiffs incorporate by reference all of the above paragraphs of this  Complaint as though fully stated herein.   52. The foregoing acts and omissions constitute numerous and multiple violations  of the FDCPA.   53. As a result of each and every violation of the FDCPA, Plaintiffs are entitled to  any actual damages pursuant to 15 U.S.C. § 1692k(a)(1); statutory damages  for a knowing or willful violation in the amount up to $1,000.00 pursuant to  15 U.S.C. § 1692k(a)(2)(A); and reasonable attorney’s fees and costs pursuant  to 15 U.S.C. § 1692k(a)(3) from Defendant.  54. Plaintiffs incorporate by reference all of the above paragraphs of this  Complaint as though fully stated herein.   55. The foregoing acts and omissions constitute numerous and multiple violations  of the RFDCPA.   VIOLATION OF THE ROSENTHAL FAIR DEBT COLLECTION PRACTICES ACT  Cal. Civ. Code §§ 1788-1788.32 (RFDCPA)  [AGAINST DEFENDANT]   VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §§ 1692-1692(p) (FDCPA)  [AGAINST DEFENDANT]  