10.  Defendant’s collection communications are to be interpreted under an  unsophisticated or least sophisticated consumer standard, see, Goswami v. Am.Collections  Enter., Inc., 377 F.3d 488, 495 (5th Cir. 2004); McMurray v. ProCollect, Inc., 687 F.3d 665, 669  (5th Cir. 2012).  11.  Plaintiff adopts and realleges ¶¶ 1-10.   12.      Section 1692e of the FDCPA prohibits a debt collector from using any false,  deceptive or misleading representation or means in connection with the collection of any debt,  see, 15 U.S.C. § 1692e.   13.  Making a false statement as to the name of the original creditor is a materially  misleading statement, which violates of § 1692e of the FDCPA, see, Tourgeman, 755 F.3d at  1120-1122. By stating that Second Round Sub, LLC was the original creditor when, in fact, it  was not, Defendant’s letter violated § 1692e of the FDCPA.     14.  Defendant’s violation of § 1692e of the FDCPA renders it liable for statutory  damages, costs, and reasonable attorneys’ fees, see, 15 U.S.C. § 1692k.  15.  Plaintiff adopts and realleges ¶¶ 1-10.   17.  Defendant, by wrongly stating that Second Round Sub was the original creditor  when, in fact, it was not the original creditor, used unfair or unconscionable means to collect a  debt, in violation of § 1692f of the FDCPA.     18.  Defendant’s violation of § 1692f of the FDCPA renders it liable for statutory  damages, costs, and reasonable attorneys’ fees, see, 15 U.S.C. § 1692k.  19.  Plaintiff, Vickie Kelly, brings this action individually and as a class action on  behalf of all persons similarly situated in the State of Mississippi from whom Defendant  attempted to collect a defaulted consumer debt, via the same form collection letter (Exhibit A),  that Defendant sent to Plaintiff, from one year before the date of this Complaint to the present.  This action seeks a finding that Defendant’s form letter violates the FDCPA and asks that the  Court award damages as authorized by § 1692k(a)(2) of the FDCPA.   20.  Defendant regularly engages in debt collection, using the same form collection  letter it sent Ms. Kelly, in its attempts to collect defaulted consumer debts from other consumers.   21.  The Class consists of more than 35 persons from whom Defendant attempted to  collect defaulted consumer debts by sending other consumers the same form collection letter it  sent Ms. Kelly.   23.  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. Defendant has acted in a manner                                                                                                                         applicable to the Class as a whole, such that declaratory relief is warranted.   24.  Plaintiff will fairly and adequately protect and represent the interests of the Class.   The management of the class action proposed is not extraordinarily difficult, and the factual and  legal issues raised by this class action complaint 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 class action litigation, including class actions brought under the FDCPA.  5.  Defendant sent Ms. Kelly a form collection letter, dated February 1, 2019, which  stated:  Current Creditor:   Second Round, LP  Original Creditor:       Second Round Sub, LLC    A copy of Defendant’s letter is attached as Exhibit A.   6.  In fact, Second Round Sub was never the “original” creditor to whom Ms. Kelly  owed a debt. Ms. Kelly is informed and believes through her counsel that the original creditor for  the account at issue was Comenity Bank for a Woman Within credit account.   7.  Violations of the FDCPA which would lead a consumer to alter his or her course  of action as to whether to pay a debt, or which would be a factor in the consumer's decision  making process, are material, see, Lox v. CDA, 689 F.3d 818, 827 (7th Cir. 2012). Moreover, the  mis-identification of creditor information is such a factor because, amongst other things, it is a  factor for a consumer in determining whether an attempt to collect a debt is fraudulent, see,  Tourgeman v. Collins Fin. Servs., 755 F.3d 1109, 1120-1122 (9th Cir. 2014), and Janetos v.  Fulton, Friedman & Gullace, 825 F.3d 317, 324-325 (7th Cir. 2016).   9.  Defendant’s collection actions complained of herein occurred within one year of  the date of this Complaint.     Violation Of § 1692f Of The FDCPA --  Unfair Or Unconscionable Collection Actions   Violation Of § 1692e Of The FDCPA –  False, Deceptive Or Misleading Collection Actions  