10.  The envelope also provides data symbols similar to a QR code through the glass window  of the letter.    11.  Courts have repeatedly found such information to directly violate §1692f(8) of the FDCPA  which clearly prohibits any language or symbol other than a business name on the outside of an  envelope.   12.  Plaintiff brings this as a class action pursuant to Fed. R. Civ. P. 23 on behalf of himself and  all others similarly situated who have received similar debt collection notices and/or  communications from Defendant which, as alleged herein, are in violation of the FDCPA.   14.  Excluded from the Class is Defendant herein, and any person, firm, trust, corporation, or  other entity related to or affiliated with the Defendant, including, without limitation, persons who  are officers, directors, employees, associates or partners of Defendant.    Numerosity   15.  Upon information and belief, Defendant has sent similar collection letters in attempt to  collect a debt to hundreds of consumers throughout the State of Pennsylvania, each of which  violates the FDCPA. The members of the Class, therefore, are believed to be so numerous that  joinder of all members is impracticable.   16.  The letters sent by Defendant and received by the Class, are to be evaluated by the objective  standard of the hypothetical “least sophisticated consumer.”   17.  The exact number and identities of the Class members are unknown at this time and can  only be ascertained through discovery. Identification of the Class members is a matter capable of  ministerial determination from Defendant’s records.   Common Questions of Law and Fact   19.  The Plaintiff's claims are typical of the claims of the class members.  Plaintiff and all  members of the Plaintiff's Class defined in this complaint have claims arising out of the Credit  America’s common uniform course of conduct complained of herein. Plaintiff's claims are typical  of the claims of the Class, and Plaintiff has no interests adverse or antagonistic to the interests of  other members of the Class.  Protecting the Interests of the Class Members   20.  Plaintiff will fairly and adequately represent the Class members' interests, in that the  Plaintiff's counsel is experienced and, further, anticipates no impediments in the pursuit and  maintenance of the class action as sought herein.    21.  Neither the Plaintiff nor her counsel have any interests, which might cause them not to  vigorously pursue the instant class action lawsuit.  Proceeding Via Class Action is Superior and Advisable   22.  A class action is superior to other methods for the fair and efficient adjudication of the  claims herein asserted, this being specifically envisioned by Congress as a principal means of  enforcing the FDCPA, as codified by 15 U.S.C.§ 1692(k).   23.  The members of the Class are generally unsophisticated individuals, whose rights will not  be vindicated in the absence of a class action.   25.  Certification of a class under Rule 23(b)(2) of the Federal Rules of Civil Procedure is also  appropriate in that a determination that the said letters violate the FDCPA is tantamount to  declaratory relief and any monetary relief under the FDCPA would be merely incidental to that  determination.   26.  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's 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.   27.  Depending on the outcome of further investigation and discovery, Plaintiff may, at the time  of class certification motion, seek to certify one or more classes only as to particular issues pursuant  to Fed. R. Civ. P. 23(c)(4).   28.  A class action will permit a large number of similarly situated persons to prosecute their  common claims in a single forum simultaneously, efficiently, and without the duplication of effort  and expense that numerous individual actions would engender. Class treatment also will permit the  adjudication of relatively small claims by many Class members who could not otherwise afford to  seek legal redress for the wrongs complained of herein.   29.  Absent a class action, the Class members will continue to suffer losses borne from  Defendant’s breaches of Class members' statutorily protected rights as well as monetary damages,  thus allowing and enabling: (a) Defendant’s conduct to proceed and; (b) Defendant to further enjoy  the benefit of their ill-gotten gains.   30.  Defendant has acted, and will act, on grounds generally applicable to the entire Class,  thereby making appropriate a final injunctive relief or corresponding declaratory relief with respect  to the Class as a whole.  31.  Plaintiff repeats the allegations contained in the above paragraphs and incorporates them as  if specifically set forth at length herein.   32.  Defendant engaged in unfair and deceptive acts and practices, in violation of 15 U.S.C. §  1692f(8).  WHEREFORE, Plaintiff, Tatenda Nyanhongo, respectfully requests that this Court do the  following for the benefit of Plaintiff:  a. Enter an Order declaring Defendant’s actions, as described above, in violation of  the FDCPA;  b. Enter an Order for injunctive relief prohibiting such conduct in the future;  c. Appoint Plaintiff as the Class Representative, and appoint Plaintiff’s Counsel as  Lead Counsel for the Class;  d. Enter a judgment against Defendant for statutory damages, pursuant to 15 U.S.C. §  1692k;  e. Award costs and reasonable attorneys’ fees, pursuant to 15 U.S.C. § 1692k; and  f.  Grant such other and further relief as may be just and proper.  6.  On March 4, 2020, Defendant mailed a collection letter to Plaintiff’s address. The letter  sought to collect a personal debt from Plaintiff that was incurred through a personal insurance bill.    7.  The letter is not compliant with the FDCPA.    8.  The letter arrived at Plaintiff’s address with additional information on the outside of the  envelope.    9.  The envelope explicitly states PERSONAL & CONFIDENTIAL.   The Class  