11.  Plaintiff brings this action as a state-wide class action, pursuant to Rule 23 of the  FRCP, on behalf of himself and all New Jersey consumers and their successors in interest (the  “Class”), who were harmed by the Defendant’s conduct in violation of the FDCPA, as described  in this Complaint.   12.  This Action is properly maintained as a class action. The Class is initially defined  as:  All New Jersey consumers for whom Defendant communicated to any person  credit information, which is known to be false and/or for whom Defendant  failed to communicate to any person that a disputed debt was disputed as set  forth herein.  The class definition may be subsequently modified or refined.  The Class  period begins one year prior to the filing of this Action.   17. Plaintiff is at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. § 1692a(3).   18. Sometime prior to July 7, 2020, Plaintiff allegedly incurred one or more financial  obligations ("OBLIGATION or OBLIGATIONS") for which Defendant reported information to  one or more national credit reporting agencies.   19. The OBLIGATIONS arose out of a transaction, in which money, property, insurance  or services, which are the subject of the transaction, are primarily for personal, family or  household purposes.   20. Plaintiff incurred the OBLIGATIONS by obtaining goods and services which were  primarily for personal, family and household purposes.   22. The OBLIGATIONS did not arise out of a transaction that was for business use.   23. Each OBLIGATION is a "debt" as defined by 15 U.S.C. § 1692a(5).   24. At some time prior to July 7, 2020, the OBLIGATIONS were placed with Defendant  for the purpose of collection.   25. At the time the OBLIGATIONS were placed with Defendant for the purpose of  collection, the OBLIGATIONS were past due.   26. At the time the OBLIGATIONS were placed with Defendant for the purpose of  collection, the OBLIGATIONS were in default.   27. At the time the OBLIGATIONS were referred to GEM RECOVERY for the purpose  of collection, the OBLIGATIONS were in default.   28. Plaintiff caused to be delivered to Defendant a letter dated July 7, 2020, which was  addressed to Defendant.  Exhibit A, which is fully incorporated herein by reference.   29. The July 7, 2020 letter was sent to Defendant in connection with the collection of the  40. Plaintiff, on behalf of himself and others similarly situated, repeats and realleges all  prior allegations as if set forth at length herein.    41. Defendant violated 15 U.S.C. § 1692e of the FDCPA by using any false, deceptive  or misleading representation or means in connection with its attempts to collect debts from  Plaintiff and others similarly situated.   42. Defendant violated 15 U.S.C. § 1692e of the FDCPA in connection with Plaintiff  and others similarly situated.   43. By failing to communicate that the OBLIGATION was disputed to one or more of  the credit reporting bureaus, Defendant engaged in a false, deceptive or misleading  representation or means in connection with the collection of the debt.   44. Defendant violated 15 U.S.C. § 1692e(2)(A) of the FDCPA by falsely representing  the character or legal status of the debt.   45. By failing to communicate that a disputed debt was disputed, Defendant made a false  representation of the character or legal status of the debt.    46. By communicating credit information which is known to be false or should be  known to be false, Defendant made a false representation of the character or legal status of the  debt.   48. Defendant violated 15 U.S.C. § 1692e(8) of the FDCPA by communicating to any  person credit information which is known to be false or should be known to be false.   49. Defendant violated 15 U.S.C. § 1692e(8) of the FDCPA by failing to communicate  to any person that the OBLIGATION was disputed.   50. Defendant violated 15 U.S.C. § 1692e(8) of the FDCPA by failing to communicate  to one or more of the credit reporting bureaus that the OBLIGATION was disputed.   51. Section 1692e(10) prohibits the use of any false representation or deceptive means to  collect or attempt to collect any debt.   52. By failing to communicate that the OBLIGATION was disputed as described herein,  Defendant engaged in a false representation or deceptive means to collect or attempt to collect  the debt.   53. Congress enacted the FDCPA in part to eliminate abusive debt collection practices  by debt collectors.   54. Plaintiff and others similarly situated have a right to free from abusive debt  collection practices by debt collectors.   55. Plaintiff and others similarly situated have a right to have the Defendant abide by its  obligations under the FDCPA and those specifically found at 15 U.S.C. § 1692e(8).   56. Plaintiff and others similarly situated have suffered harm as a direct result of the  abusive, deceptive and unfair collection practices described herein.    57. Plaintiff has suffered damages and other harm as a direct result of the Defendants’  actions, conduct, omissions and violations of the FDCPA described herein.   FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §   1692 et seq.  VIOLATIONS   