16.  Plaintiff is a natural person allegedly obligated to pay a debt.   17.  Plaintiff’s alleged obligation arises from a transaction in which the money,  property, insurance, or services that are the subject of the transaction were incurred  primarily for personal, family, or household purposes—namely, personal dental services  (the “Debt”).     18.  Defendant uses instrumentalities of interstate commerce or the mails in a  business the principal purpose of which is the collection of any debts.   19.  Defendant regularly collects or attempts to collect, directly or indirectly,  debts owed or due, or asserted to be owed or due, another.   2) FORWARD THE ACCOUNT TO OUR ATTORNEY FOR  LITIGATION.  3) REPORT THE AMOUNT TO A NATIONAL CREDIT REPORTING  21.  A true and correct copy of Defendant’s May 28, 2019 letter is attached as  Exhibit A.   22.  Defendant’s May 28, 2019 letter purports to contain the notices required in  an initial communication by 15 U.S.C. § 1692g(a). See Exhibit A.   23.  However, Defendant’s May 28, 2019 letter states: “If you do notify us of a  dispute, we will obtain verification of the debt and mail it to you.” Exhibit A.   24.  Defendant’s May 28, 2019 letter fails to inform Plaintiff, or the least  sophisticated consumer, that the right to verification is triggered only through written  dispute. Compare § 1692g(a)(4), with Exhibit A.   25.  In connection with the collection of the Debt, Defendant sent Plaintiff a  subsequent written communication dated June 4, 2019.   26.  A true and correct copy of Defendant’s June 4, 2019 letter is attached as  Exhibit B.   27.  Defendant’s June 4, 2019 letter states, in relevant part:  29.  In connection with the collection of the Debt, Defendant sent Plaintiff a third  written communication dated June 13, 2019.   30.  A true and correct copy of Defendant’s June 13, 2019 letter is attached as  Exhibit C.    31.  Defendant’s June 13, 2019 letter states, in relevant part:  33.  Plaintiff repeats and re-alleges all factual allegations above.     35.  Defendant’s June 4, 2019 letter is based on a form or template, labeled  NTC/2, used to send subsequent collection letter to consumers (hereinafter “Notice #2”).   36.  Defendant’s June 13, 2019 letter is based on a form or template, labeled  NTC/3, used to send subsequent collection letter to consumers (hereinafter “Notice #3”).   37.  Upon information and belief, Defendant uses Notice #1, Notice #2, and  Notice #3 to send series of collection letters according to regularly scheduled intervals.      38.  Notice #1 purports to provide the disclosure required by 15 U.S.C. §  1692g(a)(4) but fails to inform the consumer that the right to verification is triggered only  through written dispute.   39.  Upon information and belief, Defendant has used Notice #1 to send initial  collection letters to over 40 individuals in the State of Arizona within the year prior to the  filing of the original complaint in this matter.   40.  Notice #2 demands immediate payment and threatens further collection  activity if payment is not received.    41.  Upon information and belief, Defendant has used Notice #2 to send initial  collection letters to over 40 individuals in the State of Arizona within the year prior to the  filing of the original complaint in this matter and within less than 30 days from sending the  consumer a letter purporting to provide the disclosures required by 15 U.S.C. § 1692g(a).   43.  Upon information and belief, Defendant has used Notice #3 to send initial  collection letters to over 40 individuals in the State of Arizona within the year prior to the  filing of the original complaint in this matter and within less than 20 days from sending the  consumer a letter purporting to provide the disclosures required by 15 U.S.C. § 1692g(a).   44.  Plaintiff brings this action on behalf of himself and all others similarly  situated.  Specifically, Plaintiff seeks to represent the following classes of individuals:  Initial Dun Class:  All persons with an Arizona address to whom Defendant sent a letter based  upon Notice #1, within one year before the date of the original complaint, in  connection with the collection of a consumer debt.  Overshadowing Class:  All persons with an Arizona address to whom Defendant, in connection with  the collection of a consumer debt and within one year before the date of the  original complaint, (1) sent a letter based upon Notice #2 within 30 days of  sending a letter purporting to contain the notices required by 15 U.S.C. §  1692g(a); and/or (2) sent a letter based Notice #3 within 20 days of sending  a letter purporting to contain the notices required by 15 U.S.C. § 1692g(a).   45.  The classes are averred to be so numerous that joinder of members is  impracticable.     46.  The exact number of class members is unknown to Plaintiff at this time and  can be ascertained only through appropriate discovery.     47.  The classes are ascertainable in that the names and addresses of all class  members can be identified in business records maintained by Defendant.    49.  Plaintiff’s claims are typical of those of the classes he seeks to represent.     50.  The claims of Plaintiff and of the classes originate from the same conduct,  practice, and procedure on the part of Defendant. Thus, if brought and prosecuted  individually, the claims of the members of the class would require proof of the same  material and substantive facts.   51.  Plaintiff possesses the same interests and has suffered the same injuries as  each class member. Plaintiff asserts identical claims and seeks identical relief on behalf of  the unnamed class members.     52.  Plaintiff will fairly and adequately protect the interests of the classes and has  no interests adverse to or which directly and irrevocably conflict with the interests of other  members of the classes.   53.  Plaintiff is willing and prepared to serve this Court and the proposed classes.     54.  The interests of Plaintiff are co-extensive with and not antagonistic to those  of the absent class members.     56.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(2) in that  Defendant has acted or refused to act on grounds generally applicable to the classes,  making final declaratory or injunctive relief appropriate.   57.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(3) in that the  questions of law and fact that are common to members of the classes predominate over any  questions affecting only individual members.   58.  Moreover, a class action is superior to other methods for the fair and efficient  adjudication of the controversies raised in this Complaint in that: (a) individual claims by  the class members will be impracticable as the costs of pursuit would far exceed what any  one plaintiff or class member has at stake; (b) as a result, very little litigation has  commenced over the controversies alleged in this Complaint and individual members are  unlikely to have an interest in prosecuting and controlling separate individual actions; and  (c) the concentration of litigation of these claims in one forum will achieve efficiency and  promote judicial economy.  59.  Plaintiff repeats and re-alleges each factual allegation contained above.   61.  Congress adopted “the debt validation provisions of section 1692g” to  guarantee that consumers would receive “adequate notice” of their rights under the  FDCPA. Wilson v. Quadramed Corp., 225 F.3d 350, 354 (3d Cir. 2000) (citing Miller v.  Payco–General Am. Credits, Inc., 943 F.2d 482, 484 (4th Cir. 1991)).   62.  This validation requirement is a “significant feature” of the law that aimed to  “eliminate the recurring problem of debt collectors dunning the wrong person or attempting  to collect debts which the consumer has already paid.”  See Hernandez v. Williams, Zinman  & Parham PC, 829 F.3d 1068, 1070 (9th Cir. 2016) (citing S. Rep. No. 95-382, at 4  (1977)).   63.  “To satisfy section 1692g’s requirements, the notice Congress required must  be conveyed effectively to the debtor.”  Terran v. Kaplan, 109 F.3d 1428, 1432 (9th Cir.  1997) (quoting Swanson v. Southern Oregon Credit Serv., Inc., 869 F.2d 1222, 1227 (9th  Cir. 1988)) (internal citations omitted); see also Janetos v. Fulton Friedman & Gullace,  LLP, 825 F.3d 317, 321 (7th Cir. 2016) (“When § 1692g(a) requires that a communication  include certain information, compliance demands more than simply including that  information in some unintelligible form.”).   66.  Plaintiff repeats and re-alleges each factual allegation contained above.   67.  To ensure debt collectors’ notices meaningfully convey consumers’ rights  under § 1692g, Congress has further declared that “[a]ny collection activities and  communication during the 30-day period may not overshadow or be inconsistent with the  disclosure of the consumer’s right to dispute the debt or request the name and address of  the original creditor.”  15 U.S.C. § 1692g(b).   68.  “More importantly for present purposes, the notice must not be  overshadowed or contradicted by accompanying messages from the debt collector.”   Caprio v. Healthcare Revenue Recovery Grp., LLC, 709 F.3d 142, 148-49 (3d Cir. 2013).     69.  The notice of a consumer’s rights under § 1692g may be “overshadowed” by  language within the validation letter itself.  See Gostony v. Diem Corp., 320 F. Supp. 2d  932, 938 (D. Ariz. 2003) (“The juxtaposition of two inconsistent statements’ renders the  notice invalid under § 1692g.”) (quotations removed).   VIOLATION OF 15 U.S.C. § 1692g(a)(4)   VIOLATION OF 15 U.S.C. § 1692g(b)   WE ARE ADVISING OUR CLIENT THAT THE ENTIRE CLAIM BE  FORWARDED FOR DIRECT ACTION IF PAYMENT IS NOT  RECEIVED WITHIN THE TIME FRAME STATED.   Exhibit B (emphasis in original).   