24. At all times relevant, Plaintiff is an individual residing within the State of  California.   25. Plaintiff is informed and believes, and thereon alleges, that at all time  relevant, Defendant conducted business in the State of California.    26. On or about April 2015, Plaintiff allegedly incurred financial obligations to  the Defendant 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).   37. Plaintiff brings this action on his own behalf, and on behalf of all others  similarly situated (“The Class”) and (“The Sub-Class”) who have suffered  injury in fact as a result of Defendant’s unlawful and misleading conduct.   38. Plaintiff represents, and is a member of, “The Class” defined as follows: (i) all  persons with addresses within the State of California; (ii) who were charged a  late fee by Defendant; (iii) made pursuant to a residential lease agreement; (iv)  at any time four years prior to the date of the filing of this Action.   39. Plaintiff represents, and is a member of, “The Sub-Class” defined as follows:  (i) all persons with addresses within the State of California; (ii) who were  charged a late fee by Defendant; (iii) made pursuant to a residential lease  agreement; (iv) from whom Defendant attempted to collect a rental debt; (v) at  any time one year prior to the date of the filing of this Action.   40. Defendant and their employees or agents are excluded from the Class.    55. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   56. The foregoing acts and omissions constitute numerous and multiple violations  of the RFDCPA.   57. As a result of each and every violation of the RFDCPA, Plaintiff, and the  members of The Class, are entitled to any actual damages pursuant to Cal.  Civ. Code § 1788.30(a); statutory damages for a knowing or willful violation  in the amount up to $1,000.00 pursuant to Cal. Civ. Code § 1788.30(b); and  reasonable attorney’s fees and costs pursuant to Cal. Civ. Code § 1788.30(c)  from Defendant.  58. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   VIOLATION OF THE ROSENTHAL FAIR DEBT COLLECTION PRACTICES ACT  Cal. Civ. Code §§ 1788-1788.32 (RFDCPA)   VIOLATION OF BUSINESS AND PROFESSIONS CODE § 17200  