13.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   14.  The Class consists of:   a. all individuals with addresses in the State of Nevada;  b. to whom Defendant RFGI sent a collection letter attempting to collect a consumer  debt;   c. on behalf of Defendant DRS;  d. that deceptively implied marking a collection item as “Paid” on a credit report  would offer a resolution of the consumer’s credit report;   e. which letter was sent on or after a date one (1) year prior to the filing of this action  and on or before a date twenty-one (2l) days after the filing of this action.   15.  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.   17.  There are questions of law and fact common to the Plaintiff Class, which common  issues predominate over any issues involving only individual class members. The principal  issue is whether the Defendant’s letter, violates 15 U.S.C. §§ l692e.   18.  The Plaintiff’s claims are typical of the class members, as all are based upon the  same facts and legal theories. The Plaintiff will fairly and adequately protect the interests of  the Plaintiff Class defined in this complaint. The Plaintiff has retained counsel with  experience in handling consumer lawsuits, complex legal issues, and class actions, and neither  the Plaintiff nor his attorneys have any interests, which might cause them not to vigorously  pursue this action.   20.  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  Class 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.   21.  Depending on the outcome of further investigation and discovery, Plaintiff 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).  22.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   24.  The Why Not/Kmart obligation arose out of transactions in which money,  property, insurance or services, which are the subject of the transaction, were primarily for  personal, family or household purposes.   25.  The alleged Why Not/Kmart obligation is a "debt" as defined by 15 U.S.C.§  1692a(5).   26.   Defendant DRS, a debt collector, and the subsequent owner of the Why  Not/Kmart debt, contracted the Defendant RFGI to collect the alleged debt.   27.  Defendants RFGI and DRS collect and attempt to collect debts incurred or alleged  to have been incurred for personal, family or household purposes on behalf of creditors using  the United States Postal Services, telephone and internet.  Violation October 1, 2019 Collection Letter   28.  On or about October 1, 2019, Defendant RFGI sent Plaintiff a collection letter on  behalf of Defendant DRS (the “Letter”) regarding the alleged debt. See Exhibit A.   29.  The Letter offers settlement options to resolve the debt for less than the balance  owed.   30.  The letter further states in pertinent part: “Upon receiving your final payment, your  account will be closed and satisfied in full! Within 30 days of your final payment clearing,  you will receive a letter stating your account has been satisfied in full and closed to keep for  your records.  We will also update any derogatory/negative marks on your credit report as “Paid” in  reference to this account within 4-6 weeks of final payment.”    32.  This is deceptive because updating the consumer’s credit report to a “Paid” status  will not deliver the resolution that the letter intends to convey, because the debt would still be  reported as a collection item without effectively any resolution on the consumer’s credit  report.   33.  It is deceptive to imply a perceived benefit of resolution to a consumer thereby  coercing them into making settlement payments when there actually is no resolution.   34.  The consumer could be misled into making a settlement payment to resolve their  credit report based on the letter, in the hopes of fully resolving their credit report when, in  actuality the benefit does not exist.    35.  As a result of Defendant’s deceptive misleading and false debt collection practices,  Plaintiff has been damaged.  36.  Plaintiff repeats, reiterates and incorporates the allegations contained in the  foregoing paragraphs with the same force and effect as if the same were set forth at length  herein.   37.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   38.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   40.  Due to the fact that Defendant's conduct violated Section 1692e et seq. of the  FDCPA, Defendant is liable to Plaintiff for actual damages, statutory damages, costs and  attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  