10. Defendant is regularly engaged, for profit, in the collection of debts  allegedly owed by consumers.   11. The principal purpose of Defendant's business is the collection of such  debts.  12. Defendant uses the mails in its debt collection business.  13. Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6).   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 known only to Defendant, the alleged Debt was  assigned or otherwise transferred to Defendant for collection.   19. At the time the alleged Debt was assigned or otherwise transferred to  Defendant for collection, the alleged Debt was in default.  20. In its efforts to collect the alleged Debt, Defendant contacted Plaintiff  by calls to Plaintiff's telephone.  35. Plaintiff repeats and realleges the foregoing paragraphs as if fully  restated herein.  36. 15 U.S.C. § 1692e prohibits a debt collector from using any false,  deceptive, or misleading representations or means in connection with the collection  of any debt.  37. 15 U.S.C. § 1692e(5) specifically prohibits threatening “to take any  action that cannot legally be taken or that is not intended to be taken.”  38. 15 U.S.C. § 1692e(10) prohibits the “use of any false representation or  deceptive means to collect or attempt to collect any debt.”  39. The Letter contains a partially shaded box in the center of the Letter  which states in bolded and enlarged font, “FINAL NOTICE”, followed by “Pay online at MidlandCredit.com or Call 877-214-7799.”  48. Plaintiff repeats and realleges the foregoing paragraphs as if fully  restated herein.  57. Plaintiff brings this action individually and as a class action on behalf  of all persons similarly situated in the State of New Jersey.  58. Plaintiff seeks to certify the following class:  59. All consumers to whom Defendant sent a collection letter 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.  9. Defendant regularly collects or attempts to collect debts asserted to be  owed to others.   