(Unjust Enrichment)   (Violations of the Fair Debt Collection Practices Act)   (Violations of M.G.L. c. 93A)   19. On information and belief, there are thousands of class members.  Therefore, the class is sufficiently  numerous such that joinder would be impracticable.      20. There are issues of law and fact common to each class, which common issues predominate over any  issues particular to individual class members.  The principal common issues are: whether Atlantic  engaged in trade or commerce in Massachusetts within the scope of M.G.L. c. 93A; §1; whether  Atlantic is a debt collector within the scope of the MDCPA and the FDCPA; whether Atlantic  was required to be licensed as a debt collector by the Division of Banks during the class  periods; whether Atlantic was licensed as a debt collector by the Division during the class  periods; whether Atlantic violated the rights of Plaintiff and class members as alleged; and  whether Atlantic’s violations of M.G.L. c. 93A were willful or knowing in nature.    21. Plaintiff’s claims are typical of the claims of class members.   Plaintiff and all class members were all  injured by being subjected to consumer debt collection activity that was prohibited by law because  Atlantic was not licensed as a debt collector in Massachusetts.  All claims are based on the same legal  theories, and all claims arise from the same unlawful conduct.   23. A class action is superior to other available methods for the fair and efficient adjudication of this  controversy, since: (a) the economic harm suffered by many individual class members is either  non-existent or not substantial, therefore, the expense and burden of individual litigation would  be economically unfeasible; and (b) the prosecution of separate lawsuits by individual class  members would entail the risk of inconsistent and conflicting adjudications that could establish  conflicting standards of conduct for Defendant; and (c) there will be no unusual or  extraordinary management difficulties in administering this case as a class action.  24. The allegations of all preceding paragraphs are incorporated herein as if fully set forth.   25. At relevant times, Atlantic was engaged in trade or commerce in Massachusetts within the scope  of M.G.L. c. 93A, §1.    26. Atlantic violated M.G.L. c. 93, §24A and M.G.L. c. 93A, §2, by engaging in the business of  consumer debt collection in Massachusetts without being licensed to do so by the Division of  Banks.   27.  Atlantic’s violations of M.G.L. c. 93, §24A and M.G.L. c. 93A, §2, were willful and knowing in  nature.   29. A pre-suit demand under M.G.L. c. 93, §9, is not required, as Atlantic does not maintain an office  or keep assets in the Commonwealth of Massachusetts.  WHEREFORE, Plaintiff prays that this Honorable Court enter judgment:  (a) Awarding her and each class member actual damages equal to monies paid to Atlantic or  creditors due to Atlantic’s unlawful conduct or statutory damages of $25.00, whichever is  greater;  (b) Doubling or trebling all actual damages awarded;  (c) Awarding interest on all damages awarded;  (d) Awarding costs and reasonable attorney’s fees;  (e) Awarding such further relief as shall be just and proper.  30. The allegations of all preceding paragraphs are incorporated herein as if fully set forth.    31. Atlantic’s unlicensed debt collection activities in Massachusetts violated the following  provisions of the FDCPA:  (a) section 1692e(5), by taking and threatening to take actions that could not legally be taken;  (b) section 1692e(10), by using deceptive means to collect or attempt to collect debts;   (c) section 1692d(1), by engaging in conduct involving the threat and use of criminal means to harm the  property of Plaintiff and class members;   (d) section 1692d, by engaging in conduct the natural consequence of which was to oppress  and abuse Plaintiff and class members.     33.  The allegations of all preceding paragraphs are incorporated herein as if fully set forth.   34.   Atlantic wrongfully and unlawfully collected consumer debts in Massachusetts without being  licensed as a debt collector by the Division of Banks.   35. Atlantic earned fees as a result of recovering money for creditors.   36. Atlantic has been unjustly enriched by obtaining fees due to its unlawful debt collection  activities.  WHEREFORE, Plaintiff prays that this Honorable Court enter judgment:  (a) Ordering Atlantic to disgorge all fees obtained due to its unlawful collection activities;  (b) Awarding interest on all monies awarded;  (c) Awarding costs and reasonable attorney’s fees;  (d) Awarding such further relief as shall be just and proper.  5. Atlantic, as its name reflects, is a collection agency.  During the time period encompassed by  this complaint, most (if not all) of the debts which Atlantic collected and attempted to collect  in Massachusetts were incurred primarily for personal, family, or household purposes,  otherwise known as “consumer” debts.   6. During the time period encompassed by this complaint, Atlantic engaged in a business in  Massachusetts the principal purpose of which was consumer debt collection.   7. During the time period encompassed by this complaint, Atlantic regularly attempted and  attempted to collect, directly or indirectly, consumer debts owed or due or asserted to be owed  or due another by Massachusetts residents.   8. During the time period encompassed by this complaint, Atlantic was a “debt collector” within  the meaning of the Fair Debt Collection Practices Act, 15 U.S.C. §1692a (“FDCPA”) and  within the meaning of the Massachusetts Debt Collection Practices Act, M.G.L. c. 93, §24  A. Facts pertaining to Atlantic  