14.  Plaintiff brings this action as a state-wide class action, pursuant to Rule 23 of the  FRCP, on behalf of himself and all New Jersey consumers and their successors in interest (the  “Class”), who Defendants collected or attempted to collect a debt from, in violation of the  FDCPA, as described in this Complaint.   17.  A Class Action is superior to other methods for the fair and efficient adjudication   of the claims herein asserted. Plaintiff anticipates no unusual difficulties in the management of  this class action.   18.  A Class Action will permit large numbers of similarly situated persons to  prosecute their common claims in a single forum simultaneously and without the duplication of  effort and expense that numerous individual actions would engender.  Class treatment will also  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.  Absent a Class  Action, class members will continue to suffer losses of statutory protected rights as well as  damages.   19.  Defendant(s) have acted on grounds generally applicable to the entire Class,  thereby making appropriate final relief with respect to the Class as a whole.  20.  Plaintiff is at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. § 1692a(3).   22.  The ZALE obligation is an open end loan as defined at N.J.S.A. 17:11C-2 and/or  a retail charge account as defined at N.J.S.A. 17:16C-1 et seq.   23.  The ZALE obligation arose out of a transaction, in which money, property,  insurance or services, which are the subject of the transaction, are primarily for personal, family  or household purposes.   24.  Plaintiff incurred the ZALE obligation by obtaining goods and services which  were primarily for personal, family and household purposes.   25.  The ZALE obligation did not arise out of a transaction that was for non-personal  use.   26.  The ZALE obligation did not arise out of a transaction that was for business use.   27.  The ZALE obligation is a "debt" as defined by 15 U.S.C. § 1692a(5).   28.  ZALE is a "creditor" as defined by 15 U.S.C. § 1692a(4).   29.  At some time prior to December 10, 2020, the ZALE obligation was allegedly  purchased by and/or sold to CVI SGP-CO.   30.  At the time the ZALE obligation was purchased by and/or sold to CVI SGP-CO,  the obligation was in default.   31.  The principal purpose of CVI SGP-CO is the collection of debts which are in  default at the time it allegedly purchases the debts.   32.  CVI SGP-CO has obtained a license and/or has registered as a collection agency  and/or as a debt collector with at least one State and/or State department or agency within the  United States within the relevant period.   34.  CVI SGP-CO is prohibited from using the word “Trust” in its name by N.J.S.A.  71.  Plaintiff, on behalf of himself and others similarly situated, repeats and realleges  all prior allegations as if set forth at length herein.   72.  Collection letters and/or notices, such as those sent by Defendants, are to be  evaluated by the objective standard of the hypothetical “least sophisticated consumer.”   73.  Defendant’s letter would cause the least sophisticated consumer to be confused  about his or her rights.   74.  Defendant’s letter would mislead the least sophisticated consumer to believe that  Defendants could legally attempt to collect the debt.   75.  Defendant’s letter would cause the least sophisticated consumer to believe that  Defendants had the legal ability to attempt to collect the debt and that CVI SGP-CO had acquired  the appropriate licenses or had otherwise complied with New Jersey regulations.   76.  A violation of New Jersey laws, despite no private cause of action, can form the  basis of a violation of the FDCPA. See Chulsky v. Hudson Law Offices, P.C., 777 F.Supp.2d 823  FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §   1692 et seq.  VIOLATIONS   