23.  As touted on its web site, Defendant first notifies an alleged debtor that his  debt has been referred to a collection agency and that if full payment is not made within 30  days, a lien will be filed on the consumer’s home.4     24.  Defendant charges consumers a fee for sending this initial collection letter.     25.  If full payment is not made within 30 days, Defendant then files a lien on the  consumer’s home, and charges the consumer additional fees for doing so.     26.  At that point, if the consumer does not resolve his debt—and Defendant’s  resulting fees—the consumer’s file would move to the “constant contact” phase, whereby  Defendant repeatedly calls and sends letters to the consumer in an attempt to collect the  alleged debt.  At the same time, Defendant tacks on an additional fee.     27.  Thereafter, if the outstanding debt still is not resolved, Defendant notifies the  consumer of its intent to foreclose on the consumer’s home and move forward with  foreclosure by advertisement.    B. EquityExperts.org, LLC’s efforts to collect an alleged debt from Plaintiff   28.  In connection with the collection of the Debt, Defendant sent Plaintiff an  initial written communication dated February 26, 2015.  A true and correct copy of  Defendant’s February 26, 2015 communication is attached hereto as Exhibit A.   30.  Defendant’s February 26, 2015 communication demanded payment of a  current balance of $560.00.  Ex. A.   31.  Defendant’s February 26, 2015 communication stated, in pertinent part:  49.  The proposed Classes satisfy Fed. R. Civ. P. 23(a)(1) because they are so  numerous that joinder of all members is impracticable.  The exact number of Class  members is unknown to Plaintiff at this time and can only be ascertained through  appropriate discovery.  The proposed Classes are ascertainable in that, upon information  and belief, the names and addresses of all members of the proposed Classes can be  identified in business records maintained by Defendant.     50.  The proposed Classes satisfy Fed. R. Civ. P. 23(a)(2) and (3) because  Plaintiff’s claims are typical of the claims of the members of the Classes.  To be sure, the  claims of Plaintiff and all of the members of the Classes originate from the same conduct,  practice and procedure on the part of Defendant and Plaintiff possesses the same interests  and has suffered the same injuries as each member of the proposed Classes.   52.  A class action is superior to all other available methods for the fair and  efficient adjudication of this controversy, since joinder of all members is impracticable.     53.  Furthermore, as the damages suffered by individual members of the Classes  may be relatively small, the expense and burden of individual litigation make it  impracticable for the members of the Classes to individually redress the wrongs done to  them.  There will be no difficulty in the management of this action as a class action.   55.  Plaintiff repeats and re-alleges each and every factual allegation contained in  Paragraphs 1-54 above   56.  15 U.S.C. § 1692e(2)(A) provides:    False or misleading representations  A debt collector may not use any false, deceptive, or  misleading representation or means in connection with the  collection of any debt.  Without limiting the general  application of the foregoing, the following conduct is a  violation of this section:  (2) The false representation of—  (A)  the character, amount, or legal status of any debt;   57.  In its February 26, 2015 communication, Defendant falsely, deceptively,  and/or misleadingly stated the amount of the Debt owed by Plaintiff by including  “collection fees” of $270 in Plaintiff’s alleged balance.   58.    Because Plaintiff did not owe any collection fees to Defendant, Defendant  violated 15 U.S.C. § 1692e(2)(A) by falsely representing the character, amount, or legal  status of the alleged Debt.  59.  Plaintiff repeats and re-alleges each and every factual allegation contained in  Paragraphs 1-54 above.   61.  Defendant violated 15 U.S.C. § 1692f(1) by charging fees and costs of  collection that were neither expressly authorized by the agreement creating the debt or by  law.   62.  Defendant also violated 15 U.S.C. § 1692f(1) by charging fees and costs of  collection that were not borne by the original creditor.  63.  Plaintiff repeats and re-alleges each and every factual allegation contained in  Paragraphs 1-54 above.   65.  Defendant’s  February  26,  2015  communication  was  its  initial  communication to Plaintiff regarding the Debt.   66.  The February 26, 2015 communication was in connection with an attempt to  collect the Debt from Plaintiff.   68.  The February 26, 2015 communication did not contain the proper disclosures  required by 15 U.S.C. §1692g, nor did Defendant provide such disclosures within five days  thereafter.   69.  Specifically, Defendant’s February 26, 2015 communication violated 15  U.S.C. §1692g(a)(4) by failing to inform Plaintiff that Defendant need only mail  verification of the debt to him, and a copy of any judgment, if he notified Defendant of his  request in writing.   70.  “Every district court to consider the issue has held that a debt collector  violates § 1692g(a) by failing to inform consumers that requests under subsections (a)(4)  and (a)(5) must be made in writing.” Osborn v. Ekpsz, LLC, 821 F. Supp. 2d 859, 870 (S.D.  Tex. 2011) (citing Bicking, 783 F. Supp. 2d at 844–46; Beasley v. Sessoms & Rogers, P.A.,  No. 5:09–CV–43–D, 2010 WL 1980083, at *6–7 (E.D.N.C. Mar. 1, 2010); Nero v. Law  Office of Sam Streeter, 655 F. Supp. 2d 200, 206 (E.D.N.Y. 2009); McCabe v. Crawford  & Co., 272 F. Supp. 2d 736, 742–44 (N.D. Ill. 2003); Carroll v. United Compucred  Collections, Inc., No. 1–99–0152, 2002 WL 31936511, at *8–9 (M.D. Tenn. Nov. 15,  2002); Grief v. Wilson, Elser, Moskowitz, Edelman & Dicker, LLP, 217 F. Supp. 2d 336,  A. EquityExperts.org, LLC’s debt collection strategy   VIOLATION OF 15 U.S.C. § 1692f(1)  On behalf of Plaintiff and the Fee Class   VIOLATION OF 15 U.S.C. §1692g(a)  On behalf of Plaintiff and the Disclosure Class   VIOLATION OF 15 U.S.C. § 1692e(2)(A)  On behalf of Plaintiff and the Fee Class  