10. The landlord never took Plaintiffs to court over the alleged unpaid balance, much less obtained a judgment against them.  12. The lease was a form contract drafted entirely by the landlord with no option for the Plaintiffs to negotiate any terms other than the length ofthe tenancy.  13. On some date between June 10,2015 and July 17, 2015—^almost immediately after Plaintiffs moved out ofthe apartment—^the landlord assigned Plaintiffs' account to Defendant for collections.  14. On July 17, 2015, Defendant sent to each ofthe named Plaintiffs a collection letter, a true and accurate copyofwhichis attachedhereto as ExhibitA and incorporated fully herein by reference. Defendant sent the individual letters to Plaintiffs' new address (also in Annandale, Virginia), where they received them.  15. The collection letter states "Interest Due" of $19.93, and furthermore states, "Your unpaid principal balance will accrue interest as a rate of006.00 percent per annum."  16. This was false. In fact, there was no interest due, and no interest accruing.  17. Virginia law governing landlord-tenant relations does not automatically provide for interest on xmpaid balances, except where a landlord has obtained a judgment against a tenant, in which case the general Virginia post-judgmentinterest rate of6 percent would apply to any such judgment.  18. In Virginia, an awardofprejudgmentinterestis discretionary with the trier of fact, not mandatory. Upper Occoquan Sewage Auth, v. Blake Constr. Co., 275 Va. 41, 63 (2008).  20. Plaintiffs each individually experienced a measurable amount ofstress and anxietyat the idea that his or her balance would continueto grow as interestcontinuedto accrue.  21. In the alternative, even ifinterest were legally allowed to accrue, the collection letter falselyrepresentedthe amountofinterestowed. On informationand belief, Defendants' letter calculatedinterest startingfrom a date prior to the Plaintiffs' allegedbreach ofan obligationto pay their landlord,and thereby stated an amountof interestin excessofany amount that could possibly be due. 30. The classes Plaintiffs seek to represent (collectively, the "Class") are defined as follows: All (i) residents ofthe states ofVirginia, West Virginia, Maryland, North Carolina, or South Carolina (ii) to whom letters of the same form or substantially similar form as Exhibit A were sent (iii) in an attempt to collect a debt arising out of a residential lease (iv) which were not returned imdelivered by the U.S. Post Office (v) during the one year period prior to the filing of the complaint in this action (the "Fourth Circuit Class"). All (i) residents of the Commonwealth of Virginia (ii) to whom letters of the same form or substantially similar form as Exhibit A were sent (iii) in an attempt to collect a debt arising out of a residential lease (iv) wMch were not returned undelivered by the U.S. Post Office (v) during the one year period prior to the filing ofthe complaint in this action (the "Virginia Sub-Class").  31. Excluded from the Classes are Defendant's officers, directors, affiliates, legal representatives, employees, successors, subsidiaries, and assigns. Also excluded from the Classes are any judges, justices, or judicial officers presiding over this matter and the members oftheir immediate families and judicial staff.  32. Plaintiffreserves the right to amend the Class definitions ifdiscovery and further investigation reveals that the Classes should be expanded or otherwise modified.  33. Plaintiffreserves the right to establish sub-classes as appropriate.  35. Numerositv: The proposed Classes are each so numerous that individual joinder ofall members is impracticable.  37. Typicality: Plaintiffs' claims are typical ofthe claims ofthe members ofthe Classes. Plaintiffs and all members ofthe Classes haye been similarly affected by Defendant's actions.  38. Adequacy ofRepresentation: Plaintiffs will fairly and adequately represent and protect the interests ofthe Classes. Plaintiffs haye retained counsel with substantial experience in prosecuting complex and class action litigation. Plaintiffs and their counsel are committed to yigorously prosecuting this action on behalfofthe Classes and haye the financial resources to do so.  40. Plaintiffs incorporate by reference the allegations in paragraphs 1-39.  41. Defendant is a "debt collector" as defined in the FDCPA, 15 U.S.C. § 1692a(6) because it uses the mails in the business ofregularly collectingor attemptingto collect debts owed or due to another.  42. Plaintiffs and class members are obligated or allegedlyobligatedto pay a debt arising outof a transaction that isprimarily forpersonal, family, orhousehold purposes and is thus a "consumer" as defined in the FDCPA, 15 U.S.C. §1692a{3).  43. The FDCPA, 15U.S.C. §1692e,prohibits the use ofany false, deceptive, or misleading representations in connection withthe collection of anydebt.  44. Themisrepresentations as setforth above in defendant's collection letter attached hereto as Exhibit A violated the FDCPA, specifically 15U.S.C. §§ 1692e(2)(A), 1692e(10), and 1692f(l), to theinjury ofPlaintiffs and class members, andDefendant is thus liable toPlaintiffs and similarly situated class members in damages. 45. Plaintiffs incorporate by reference the allegations in paragraphs 1-44.  46. The FDCPA, 15U.S.C. § 1692g,requires notificationofthe ability for a consumerto disputeor request verification ofallegeddebts within 30 days.  48. Moreover, by including an illegal amount ofinterest in the collection letter to Plaintiffs, Defendant misrepresented the actual amount alleged to be owed by Plaintiffs as required by 15 U.S.C. § 1692g(a)(l).  49. The misrepresentations set forth above in Defendant's collection letter attached hereto as Exhibit A violated the FDCPA, specifically 15 U.S.C. § 1692g and § 1692g(a)(l), to the injury ofPlaintiffs and class members, and Defendant is thus liable to Plaintiffs and similarly situated class members in damages. 8. On June 10, 2015, Plaintiffs Sara Judith Garcia Galdamez, Jorge Armando Escobar Barillas, and Virginia de Jesus Pena Pozuelos (hereinafter referred to as "Plaintiffs"), voluntarily moved out ofa rental apartment in the Fairmont Gardens apartment complex managed by Fairmont Residential, LLC in Annandale, Virginia, because their lease ended. At that time, they voluntarily turned over possession ofthe apartment to the landlord. The apartment in question had been Plaintiffs' primary residence.  9. After Plaintiffs moved out ofthe apartment, the landlord contended that they left behind an unpaid balance of$3,276.84, which allegedly consisted ofa certain amount ofunpaid rent, a certain amount ofunpaid utility bills, and charges for repair ofsome alleged minor damages to theapartment.^  Fair Debt Collectioii Practices Act 15 U.S.C. 1692e, 1692e(2)(A). 1692e(10). 1692f(l).  Fair Debt Collection Practices Act. 15 U.S.C» 1692g. 1692g(aKl). 