17.  At all times relevant, Plaintiff is and was an individual residing in the County  of San Diego, within the State of California.    18.  Upon information and belief, at all times relevant, Defendant conducted  business in the State of California.    19.  Sometime prior to April of 2017, Plaintiff allegedly incurred a debt to an  original creditor, BorrowersFirst, Inc. (“BorrowersFirst”). Afterwards, the  alleged debt was assigned, placed, or otherwise transferred to Defendant for  collection.   42. Plaintiff brings this action on behalf of himself and all others similarly situated,  as a member of the following proposed classes (the “Classes”).   43. Plaintiff represents, and is a member of Class A, consisting of:  All persons within the United States who received an  initial correspondence from Defendant or its agent/s and  or employee/s, that is identical or substantially similar to  the October 2, 2017 correspondence Plaintiff received  from Defendant, within the one year prior to the filing of  this Complaint.   54. Plaintiff repeats, re-alleges, and incorporates by reference, all other paragraphs  of this Complaint as though fully stated herein.   55. The foregoing acts and omissions constitute numerous and multiple violations  of the FDCPA, 15 U.S.C. §§ 1692, et seq., including but not limited to each  and every one of the above-cited provisions of the FDCPA.   FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §§ 1692, ET SEQ. (FDCPA)  