10. Plaintiff made various charges to the credit card for personal purposes.  11. Due to financial difficultly, Plaintiff defaulted on her Kohl’s, Inc. credit card account (“subject debt”).   12. The subject debt is a “debt” as defined by 15 U.S.C. § 1692a(5).  13. The subject debt was eventually placed with Defendant for collection.  14. On September 2, 2020, Defendant mailed Plaintiff a letter in an attempt to collect the subject debt (“Defendant’s Collection Letter”).   16.  Defendant’s Collection Letter is a “communication” as defined by 15 U.S.C. §  1692a(2).   17.  Defendant’s Collection Letter did not conspicuously identify the current creditor  as required by §1692g(a)(2) of the FDCPA.    18.  Specifically, Defendant’s Collection Letter identified “Capital One, N.A.” as the  “Original Creditor” and “Creditor” but did not identify the current creditor.   19.  Moreover, Defendant’s Collection Letter represented that “Kohl’s, Inc. has  assigned the above account to Viking Client Services, LLC for collections.”   20.  Accordingly, Defendant’s Collection Letter confused Plaintiff as she was unable to  determine whether “Kohl’s Inc.” or “Capital One, N.A.” was the current creditor to whom the  subject debt is owed to.    22.  Accordingly, Defendant’s Collection Letter failed to conspicuously identify the  current creditor as required by the FDCPA.    23.  The confusing presentation in Defendant’s Collector Letter impacted Plaintiff’s  decision to pay the subject debt.    24.  Accordingly, Plaintiff was deprived of her right to receive critical information  required by the FDCPA.   25.  All paragraphs of this Complaint are expressly adopted and incorporated herein as  though fully set forth herein.   26.  Plaintiff brings this action pursuant to and Fed. R. Civ. P. 23, individually, and on  behalf of all others similarly situated (“Putative Class”).   27.  The Putative Class is defined as follows:  All natural persons residing in the State of Florida (a) that received a  correspondence from Defendant; (b) attempting to collect a consumer debt placed  by Kohl’s Inc. with Defendant for collection; (c) that failed to conspicuously  identify the current creditor; (d) within the one (1) year preceding the date of this  complaint through the date of class certification.   29.  Upon information and belief, Defendant mailed hundreds of similar letters to  consumers nationwide.   30.  The exact number of members of the Putative Class are unknown and not available  to Plaintiff at this time, but it is clear that individual joinder is impracticable.     31.  Members of the Putative Class can be objectively identified from records of  Defendant to be gained in discovery.  B.  Commonality and Predominance:    32.  There are many questions of law and fact common to the claims of Plaintiff and the  Putative Class, and those questions predominate over any questions that may affect individual  members of the Putative Class.    C.  Typicality:   33.  Plaintiff’s claims are representative of the claims of other members of the Putative  Class.   34.  Plaintiff’s claims are typical of members of the Putative Class because Plaintiff and  members of the Putative Class are entitled to damages as result of Defendant’s conduct.  D.  Superiority and Manageability:    35.  This case is also appropriate for class certification as class proceedings are superior  to all other available methods for the efficient and fair adjudication of this controversy.     36.  The damages suffered by the individual members of the Putative Class will likely  be relatively small, especially given the burden and expense required for individual prosecution.   38.  Economies of effort, expense, and time will be fostered and uniformity of decisions  ensured.  E.  Adequate Representation:    39.  Plaintiff will adequately and fairly represent and protect the interests of the Putative  Class.   40.  Plaintiff has no interests antagonistic to those of the Putative Class, and Defendant  has no defenses unique to Plaintiff.   41.  Plaintiff has retained competent and experienced counsel with substantial  experience in consumer law.  42.  All Paragraphs of this Complaint are expressly adopted and incorporated herein as  though fully set forth herein.  Violation(s) of 15 U.S.C. § 1692g   44.  Section 1692g of the FDCPA requires debt collectors to make certain disclosures,  including the identity of the current creditor.    45.  Defendant violated 15 U.S.C. §1692g by failing to adequately provide Plaintiff with  the disclosures required by the FDCPA   46.  As set forth above, Defendant’s Collection Letter violated §1692g(a)(2) because it  failed  to conspicuously identify the current creditor to whom the debt is owed. See Steffek v.  Client Services, Inc., 948 F.3d 761, 765 (7th Cir. 2020) (finding that the mere presence of the  correct name of the current creditor is insufficient to satisfy the requirements of §1692g(a)(2)).    47.  As pled above, Plaintiff was deprived of critical information required by the  FDCPA and the confusing presentation in Defendant’s Collection Letter impacted Plaintiff’s  decision to pay the subject debt.   WHEREFORE, Plaintiff requests the following relief:  A.  Declaring that Defendant’s Collection Letter violates Section 1692g(a)(2) of the  9. Plaintiff applied for and obtained a Kohl’s Inc. credit card.  Fair Debt Collection Practices Act (15 U.S.C. § 1692 et seq.)  (On behalf of Plaintiff and the Member of Putative Class)  