19.  Defendant regularly collects or attempts to collect debts asserted to be owed to  others.     20.  Defendant is regularly engaged, for profit, in the collection of debts allegedly owed  by consumers.    21.  The principal purpose of Defendant's business is the collection of such debts.  4   22.  Defendant uses the mails in its debt collection business.   23.  Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6).    24.  Defendant alleges Plaintiff owes a debt (the “alleged Debt”).     25.  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.   26.  The alleged Debt does not arise from any business enterprise of Plaintiff.   27.  The alleged Debt is a “debt” as defined by 15 U.S.C. § 1692a(5).   28.  At an exact time known only to Defendant, the alleged Debt was assigned or  otherwise transferred to Defendant for collection.    29.  At the time the alleged Debt was assigned or otherwise transferred to Defendant for  collection, the alleged Debt was in default.   30.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff by calls to  Plaintiff's telephone.   31.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff in writing,  including by letter dated February 13, 2021 (the “Letter”). (A true and accurate copy of the Letter  is annexed hereto as Exhibit 1).   32.  The Letter was the initial written communication Plaintiff received from Defendant  concerning the alleged Debt.   33.  The Letter conveyed information regarding the alleged Debt.   34.  The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).    35.  The Letter was received and read by Plaintiff.   36.  15 U.S.C. § 1692g protects Plaintiff's concrete interests. Plaintiff has the interest  and right to receive a clear, accurate and unambiguous validation notice, which allows a consumer  to confirm that he or she owes the debt sought to be collected by the debt collector. As set forth  herein, Defendant deprived Plaintiff of this right.   37.  15 U.S.C. § 1692e protects Plaintiff's concrete interests. Plaintiff has the interest  and right to be free from deceptive and/or misleading communications from Defendant. As set  forth herein, Defendant deprived Plaintiff of this right.   38.  Plaintiff's injury is “particularized” and “actual” in that the letter that caused the  injury was addressed and sent to Plaintiff specifically.   5   39.  Plaintiff's injury is directly traceable to Defendant's conduct, because Defendant  sent the Letter.    40.  A favorable judicial resolution of Plaintiff's case would redress Plaintiff's injury  with damages.    41.  The deprivation of Plaintiff's rights will be redressed by a favorable decision herein.     42.  Plaintiff has been misled by Defendant's actions.    43.  Plaintiff justifiably fears that, absent this Court's intervention, Defendant will  continue to use abusive, deceptive, unfair and unlawful means in its attempts to collect the Debt.   44.  Plaintiff justifiably fears that, absent this Court's intervention, Defendant will  ultimately cause him unwarranted economic harm.   45.  As a result of Defendant's conduct, Plaintiff was forced to hire counsel and  therefore has incurred damages including reasonable attorneys' fees in reviewing Plaintiff's rights  under the law and prosecuting this claim.   46.  As a result of Defendant's conduct, Plaintiff's counsel was forced to expend time  and money to investigate the enforceability of the Debt.   47.  Upon information and belief, Plaintiff can prove that all actions taken by Defendant  as described in this Complaint were taken willfully, with either the desire to harm Plaintiff with  knowledge that its actions would very likely harm Plaintiff, and/or with knowledge that its actions  were taken in violation of the law.  48.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.   49.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.   50.  As relevant here, 15 U.S.C. § 1692g(a)(2) requires the written notice provide the  name of the creditor to whom the debt is owed.   51.  To comply with 15 U.S.C. § 1692g(a)(2), a statement of the name of the creditor to  whom the debt is owed must clearly, accurately and without ambiguity convey, from the  perspective of the least sophisticated consumer, the actual name of the creditor to whom the debt  is owed.  6   52.  Even if a debt collector conveys the required information, the debt collector  nonetheless violates the 15 U.S.C. § 1692g(a)(2) if it conveys that information in a confusing or  contradictory fashion so as to cloud the required message with uncertainty in the eyes of the least  sophisticated consumer.   53.  Merely naming an entity without specifically identifying the entity as the creditor  to whom the debt is owed is not sufficient to comply with 15 U.S.C. § 1692g(a)(2).    54.  The Letter fails to clearly identify the name of the creditor to whom the debt is  owed.   55.  The Letter states “Please allow this letter to intrudce Jefferson Capital Systems,  LLC as the owner and current creditor of your referenced account.    56.  The Letter lists “Cellco Pasrtnership DBA Verizon Wireless” as the “Original  Creditor.”   57.  The Letter then lists “Verizon” as the “Current Creditor.”   58.  The Letter fails to indicate the name of Plaintiff's creditor to whom the alleged Debt  is owed in a manner that is clear and unambiguous.   59.  The least sophisticated consumer could read the Letter and be led to believe that   Cellco Pasrtnership DBA Verizon Wireless  is his creditor.   60.  The least sophisticated consumer could read the Letter and be led to believe that   Verizon is his creditor.   61.  The least sophisticated consumer could read the Letter and be led to believe that   Jefferson Capital Systems, LLC is his creditor.   62.  The Letter fails to indicate the owner of the alleged Debt clearly and without  ambiguity.   63.  The Letter fails to indicate who referred the account to Defendant.     64.  The Letter fails to indicate who Defendant represents.    65.  The Letter fails to indicate the name of any entity to which payment should be  made.     66.  As a result of such failures, Defendant did not clearly convey, from the perspective  of the least sophisticated consumer, the owner of the alleged Debt as required by 15 U.S.C. §  1692g(a)(2).   67.  As a result of such failures, the least sophisticated consumer would likely be  7  confused and uncertain as to the owner of the alleged Debt.   68.  As a result of such failures, Defendant did not clearly, accurately and without  ambiguity convey, from the perspective of the least sophisticated consumer, the creditor to whom  the alleged Debt is owed as required by 15 U.S.C. § 1692g(a)(2).    69.  15 U.S.C. § 1692e prohibits a debt collector from using any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   70.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     71.  A debt collection practice can be a “false, deceptive, or misleading” practice in  violation of 15 U.S.C. § 1692e even if it does not fall within any of the subsections of 15 U.S.C. §  1692e.     72.  A collection letter violates 15 U.S.C. § 1692e if, in the eyes of the least  sophisticated consumer, it is open to more than one reasonable interpretation, at least one of which  is inaccurate.    73.  A collection letter also violates 15 U.S.C. § 1692e if it is reasonably susceptible to  an inaccurate reading by the least sophisticated consumer.     74.  For purposes of 15 U.S.C. § 1692e, the failure to clearly and accurately identify the  owner of a debt is unfair and deceptive to the least sophisticated consumer.    75.  The owner of a debt must be clearly, accurately, accurately and without ambiguity  conveyed from the perspective of the least sophisticated consumer.   76.  The identity of the owner of a debt is a material piece of information to a consumer.   77.  Knowing the identity of the owner of a debt affects how a consumer responds to a  debt collector's attempts to collect the debt.    78.  Defendant failed to explicitly state the owner of the alleged Debt.   79.  Defendant failed to clearly state the owner of the alleged Debt.   80.  The least sophisticated consumer would likely be confused as to the owner of the  alleged Debt.   81.  The least sophisticated consumer would likely be uncertain as to owner of the  alleged Debt.   8   82.  Because the Letter can reasonably be read by the least sophisticated consumer to  have two or more meanings concerning the owner of the alleged Debt, one of which is inaccurate  as described, it is deceptive within the meaning of 15 U.S.C. § 1692e.   83.  Because the Letter is reasonably susceptible to an inaccurate reading by the least  sophisticated consumer concerning the owner of the alleged Debt as described, it is deceptive  within the meaning of 15 U.S.C. § 1692e.   84.  The least sophisticated consumer would likely be deceived by the Letter.     85.  The least sophisticated consumer would likely be deceived in a material way by the  Letter.   86.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692g(a)(2), 1692e and  1692e(10) and is liable to Plaintiff therefor.  87.  Plaintiff brings claims, pursuant to the Federal Rules of Civil Procedure (hereinafter  “FRCP”) Rule 23, individually and on behalf of the following consumer classes (the “Class”)  consisting of:   a. All consumers who have an address the State of New York.  b. who were sent a collection letter from the Defendant   c. attempting to collect a consumer debt   d. which states “Jefferson Capital Systems, LLC as the owner and current  creditor” that lists more than one “Current Creditor.”   e. That lists “Cellco Partnership DBA Verizon Wireless” as Original Creditor.  f. That purports Jefferson Capital Systems, LLC to be the owner and current  creditor but lists “Verizon” as Current Creditor.   g. which letter was sent on or after a date one year prior to the filing of this  action and on or before a date 21 days after the filing of this action.    88.  The identities of all class members are readily ascertainable from the records of  Defendants and those companies and entities on whose behalf they attempt to collect and/or have  purchased debts.    89.  Excluded from the Plaintiff Classes are the Defendants and all officers, members,  partners, managers, directors, and employees of the Defendants and their respective immediate  families, and legal counsel for all parties to this action and all members of their immediate families.   9   90.  There are questions of law and fact common to the Plaintiff Classes, which common  issues predominate over any issues involving only individual class members. The principal issue  is whether the Defendants' written communications to consumers, in the forms attached as Exhibit  1, violates the FDCPA for the reasons set forth herein.   91.  The Plaintiffs' claims are typical of the class members, as all are based upon the  same facts and legal theories.    92.  The Plaintiffs will fairly and adequately protect the interests of the Plaintiff Classes  defined in this complaint.    93.  The Plaintiffs have retained counsel with experience in handling consumer  lawsuits, complex legal issues, and class actions, and neither the Plaintiffs nor their attorneys have  any interests, which might cause them not to vigorously pursue this action.    94.  This action has been brought, and may properly be maintained, as a class action  pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure because there is a  well-defined community interest in the litigation:   a. Numerosity: The Plaintiffs are informed and believe, and on that basis allege, that the  Plaintiff Classes defined above are so numerous that joinder of all members would be  impractical.   b. Common Questions Predominate: Common questions of law and fact exist as to all  members of the Plaintiff Classes and those questions predominate over any questions  or issues involving only individual class members. The principal issue is whether the  Defendants' written communications to consumers, in the forms attached as Exhibit 1,  violates the FDCPA.  c. Typicality: The Plaintiffs' claims are typical of the claims of the class members. The  Plaintiffs and all members of the Plaintiff Classes have claims arising out of the  Defendants' common uniform course of conduct complained of herein.   d. Adequacy: The Plaintiffs will fairly and adequately protect the interests of the class  members insofar as Plaintiffs have no interests that are averse to the absent class  members. The Plaintiffs are committed to vigorously litigating this matter. Plaintiffs  have also retained counsel experienced in handling consumer lawsuits, complex legal  issues, and class actions. Neither the Plaintiffs nor their counsel have any interests  which might cause them not to vigorously pursue the instant class action lawsuit.   10  e. Superiority: A class action is superior to the other available means for the fair and  efficient adjudication of this controversy because individual joinder of all members  would be impracticable. Class action treatment will permit a large number of similarly  situated persons to prosecute their common claims in a single forum efficiently and  without unnecessary duplication of effort and expense that individual actions would  engender.    95.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff Classes  predominate over any questions affecting an individual member, and a class action is superior to  other available methods for the fair and efficient adjudication of the controversy.   96.  Depending on the outcome of further investigation and discovery, Plaintiffs may,  at the time of class certification motion, seek to certify a class(es) only as to particular issues  pursuant to Fed. R. Civ. P. 23(c)(4).   97.  The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of the  Class, and a risk that any adjudications with respect to individual members of the Class would, as  a practical matter, either be dispositive of the interests of other members of the Class not party to  the adjudication, or substantially impair or impede their ability to protect their interests.     98.  The management of the class is not extraordinarily difficult, and the factual and  legal issues raised by this action will not require extended contact with the members of the Class,  because Defendant's conduct was perpetrated on all members of the Class and will be established  by common proof.  Moreover, Plaintiff has retained counsel experienced in actions brought under  consumer protection laws. 