14.  Defendant alleges Plaintiff owes a debt (“the alleged Debt”).     15.  The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of a  transaction in which the money, property, insurance, or services which are the subject of the  transaction are primarily for personal, family, or household purposes.   16.  The alleged Debt does not arise from any business enterprise of Plaintiff.   17.  The alleged Debt is a “debt” as defined by 15 U.S.C. § 1692a(5).   18.  At an exact time known only to Defendant, the alleged Debt was assigned or  otherwise transferred to Defendant for collection.    19.  At the time the alleged Debt was assigned or otherwise transferred to Defendant for  collection, the alleged Debt was in default.   20.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff by calls to  Plaintiff's telephone.  3   21.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff by letters  including the letter dated January 16, 2020 (“the Letter”). (A true and accurate copy is annexed  hereto as “Exhibit 1.”)   22.  The Letter conveyed information regarding the alleged Debt.   23.  The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).    24.  The Letter was the initial written communication Plaintiff received from Defendant  concerning the alleged Debt.   25.  The Letter was received and read by Plaintiff.   26.  15 U.S.C. § 1692g protects Plaintiff's concrete interests. Plaintiff has the interest  and right to receive a clear, accurate and unambiguous validation notice, which allows a consumer  to confirm that he or she owes the debt sought to be collected by the debt collector. As set forth  herein, Defendant deprived Plaintiff of this right.   27.  15 U.S.C. § 1692e protects Plaintiff's concrete interests. Plaintiff has the interest  and right to be free from deceptive and/or misleading communications from Defendant. As set  forth herein, Defendant deprived Plaintiff of this right.   28.  The deprivation of Plaintiff's rights will be redressed by a favorable decision herein.   29.  As relevant here, 15 U.S.C. § 1692g(a)(1) requires the written notice provide “the  amount of the debt.”   30.  To comply with 15 U.S.C. § 1692g(a)(1), a statement of “the amount of the debt”  must clearly convey, from the perspective of the least sophisticated consumer, the actual amount  of the debt.   31.  To comply with 15 U.S.C. § 1692g(a)(1), a statement of “the amount of the debt”  must accurately convey, from the perspective of the least sophisticated consumer, the actual  amount of the debt.   32.  To comply with 15 U.S.C. § 1692g(a)(1), a statement of “the amount of the debt”  must convey without ambiguity, from the perspective of the least sophisticated consumer, the  actual amount of the debt.   33.  The failure to include the foregoing information renders an otherwise accurate  statement of the “amount of the debt” violative of 15 U.S.C. § 1692g(a)(1).   34.  15 U.S.C. § 1692e prohibits a debt collector from using any false, deceptive, or  misleading representation or means in connection with the collection of any debt.  4   35.  15 U.S.C. § 1692e(2)(A) prohibits the false representation of the character, amount,  or legal status of any debt.   36.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     37.  A debt collection practice can be a “false, deceptive, or misleading” practice in  violation of 15 U.S.C. § 1692e even if it does not fall within any of the subsections of 15 U.S.C. §  1692e.     38.  A collection letter violates 15 U.S.C. § 1692e if, in the eyes of the least  sophisticated consumer it is open to more than one reasonable interpretation, at least one of which  is inaccurate.   39.  A collection letter also violates 15 U.S.C. § 1692e if, it is reasonably susceptible to  an inaccurate reading by the least sophisticated consumer.    40.  The Letter states in a tabular column, “AMOUNT DUE AT CHARGEOFF:  $178.20.”   41.  The Letter additionally states in the same tabular column, “TOTAL PAYMENTS  53.  Plaintiff brings this action individually and as a class action on behalf of all persons  similarly situated in the State of New York.   54.  Plaintiff seeks to certify a class of:  All consumers to whom Defendant sent a collection letter substantially  and materially similar to the letter sent to Plaintiff, which letter was  sent on or after a date one year prior to the filing of this action to the  present.   55.  This action seeks a finding that Defendant's conduct violates the FDCPA and asks  that the Court award damages as authorized by 15 U.S.C. § 1692k.   56.  The Class consists of more than thirty-five persons.   57.  Plaintiff's claims are typical of the claims of the Class.  Common questions of law  or fact raised by this action affect all members of the Class and predominate over any individual  issues.  Common relief is therefore sought on behalf of all members of the Class.  A class action is  superior to other available methods for the fair and efficient adjudication of this controversy.   58.  The prosecution of separate actions by individual members of the Class would  6  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.   59.  Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class is not extraordinarily difficult, and the factual and legal issues raised  by this action 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 actions brought under consumer protection  laws. 