14.  Defendant alleges Plaintiff owes a debt ("the alleged Debt").   15.  The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of a  transaction in which the money, property, insurance, or services which are the subject of the  transaction are primarily for personal, family, or household purposes.   16.  The alleged Debt does not arise from any business enterprise of Plaintiff.   17.  The alleged Debt is a "debt" as defined by 15 U.S.C. § 1692a(5).   18.  At an exact time knovm only to Defendant, the alleged Debt was assigned or  otherwise transf ened to Defendant for collection.   19.  At the time the alleged Debt was assigned or otherwise transfe1Tecl to Defendant for  collection, the alleged Debt was in default.   21.  The Letter conveyed information regarding the alleged Debt.   22.  Th.e Letter is a "communication" as defined by 15 U.S.C. § l 692a(2).   23.  The Letter was received and read by Plaintiff.   24.  15 U.S.C. § 1692e protects Plaintiff's concrete interests. Plaintiff has the interest  and right to be free from deceptive and/or misleading communications from Defendant. As set  forth herein, Defendant deprived Plaintiff of this right.   25.  15 U.S.C. § 1692e prohibits a debt collector from using any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   26.  15 U.S.C. § l 692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.   27.  A debt collection practice can be a "false, deceptive, or misleading" practice in  violation of 15 U.S.C. § 1692e even if it docs not fall within any of the subsections of 15 U.S.C. §  1692e.   28.  A collection letter violates 15 U.S.C. § 1692e if: in the eyes of the least  sophisticated consumer it is open to more than one reasonable interpretation, at least one of which  is inaccurate.   29.  A collection letter also violates 15 U.S.C. § 1692e if it is reasonably susceptible to  an inaccurate reading by the least sophisticated consumer.   30.  For purposes of 15 U.S.C. § 1692e, the failure to clearly and accmately identify the  owner of a debt is unfair and deceptive to the least sophisticated consumer.   31.  The owner of a debt must be clearly conveyed from the perspective of the least  sophisticated consumer.   32.  The owner of a debt must be accurately conveyed from the perspective of the least  sophisticated consumer.   33.  The owner of a debt must be conveyed without ambiguity from the perspective of  the least sophisticated consumer.   34.  The identity of the owner of a debt is a material piece of information to a consumer.   35.  Knowing the identity of the ow11er of a debt affects how a consumer responds to a  debt collector's attempts to collect the debt.   37.  Rather, the Letter provides only, "Original Creditor: JPMORGAN CHASE BANK  4 7.  Plaintiff brings this action individually and as a class action on behalf of all persons  similarly situated in the State of Pennsylvania.   48.  Plaintiff seeks to certify a class of:  All consumers to whom Defendant sent a collection letter failing to  explicitly state the owner of the alleged Debt, substantially and  materially similar to the Letter sent to Plaintiff: which letter was sent  on or after a date one year prior to the filing of this action to the present.   50.  The Class consists of more than thirty-five persons.   51.  Plaintiffs claims are typical of the claims of the Class. Common questions of law  or fact raised by this action affect all members of the Class and predominate over any individual  issues. Common relief is therefore sought on behalf of all members of the Class. A class action is  superior to other available methods for the fair and efficient adjudication of this controversy.   52.  The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of the  Class, and a risk that any adjudications with respect to individual members of the Class would, as  a practical matter, either be dispositive of the interests of other members of the Class not party to  the adjudication, or substantially impair or impede their ability to protect their interests. Defendant  has acted in a manner applicable to the Class as a whole such that declaratory relief is warranted.   53.  Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class is not extraordinarily difficult, and the factual and legal issues raised  by this action will not require extended contact with the members of the Class, because Defendant's  conduct was perpetrated on all members of the Class and ,vill be established by common proof.  Moreover, Plaintiff has retained counsel experienced in actions brought under consumer protection  laws.  I I I  I I I I I I I I  LAST NAME I I I I I  NCI ID: - 1817  ACCOUNT BALANCE: $3,532.78 