16.  Defendant has alleged that, sometime prior to August 21, 2012,  ALCANTARA incurred a financial obligation (“ALCANTARA DEBT”) to Citibank  South Dakota, N.A./Home Depot.   17.  Defendant has alleged that Jackson Capital, Inc. (“JACKSON”), a New  Jersey for-profit corporation, purchased the ALCANTARA DEBT.   18.  Defendant has alleged that the ALCANTARA DEBT is in default.   19.  ALCANTARA never incurred any debts in connection with a business or  commercial activities and, therefore, the ALCANTRA DEBT, if truly an obligation owed  by him, could have only arisen from a financial obligation for primarily personal, family,  or household purposes.   20.  The ALCANTARA DEBT is a “debt” as defined by 15 U.S.C. § 1692a(5).   21.   ALCANTARA is, at all relevant times to this complaint, a “consumer” as  defined by 15 U.S.C. § 1692a(3).   22.  JACKSON purchased defaulted debt and collects, and attempts to collect,  debts incurred, or alleged to have been incurred, for personal, family, or household  purposes on behalf of creditors using U.S. Mail, telephone, and/or internet.   23.  In connection with its debt servicing operations, JACKSON outsources  collection activities to other collection agencies such, such as SMITH.    24.  JACKSON retained the services of SMITH to attempt to collect the  37.  Plaintiffs bring this action as a class action, pursuant to Rule 23 of the  Federal Rules of Civil Procedure (hereinafter “FRCP”), on behalf of themselves and all  consumers and their successors in interest (hereinafter the “Class”), who have received  debt collection letters and/or notices from SMITH which are in violation of the FDCPA,  as described in this Complaint.   40.  Plaintiffs incorporate by reference paragraphs 1-39.   41.  Defendant violated Sections 1692e(3), e(10) and 1692j of the FDCPA by  using its title and status as a lawyer and law firm to make false, deceptive or confusing  statements or forms to consumers.   42.  Defendant violated Sections 1692d, 1692e(3), e(5), e(10), and 1692f, of  the FDCPA by using the authority and credibility created by its letterhead to collect debts  and/or convey the threat of litigation, without any meaningful attorney review of the  consumer’s account.    VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. § 1692 et. seq.  