19.   MENN regularly engages in the collection of defaulted consumer debts.   2.   Unless Attorney William P. McKinley of Menn Law Firm,  Ltd. is notified of a dispute of the indebtedness within thirty  (30) days of the date hereof, the debt will be assumed to be  valid.   20.   According to its website, MENN has wide-ranging experience in business  litigation, including “Collection/creditors’ rights”. http://www.mennlaw.com/business-litigation/   21.   MENN regularly engages in the collection of defaulted consumer debts owed to  others.   22.   In attempting to collect debts, MENN uses the mail, telephone, internet, and other  instruments of interstate commerce.   23.   MENN mailed or caused to be mailed a two-page letter dated May 1, 2018 (the  “Letter”) to COLE.   24.   A true and correct copy of the Letter is attached as Exhibit A, except that the  undersigned has partially redacted it.   26.   The alleged Debt arose out of one or more transactions in which the money,  property, insurance, or services that were the subject of the transactions were primarily for  personal, family, or household purposes.   27.   The Letter was MENN’s first written communication to COLE attempting to  collect the Debt.   28.   On information and belief, sometime prior to May 1, 2018, the creditor of the  Debt either directly or through intermediate transactions assigned, placed, or transferred the debt  to MENN for collection.   29.   On the second page of the Letter, MENN stated in relevant part:   3.  If Attorney William P. McKinley of Menn law Firm, Ltd. is  notified in writing within thirty (30) days that there is some  dispute concerning the indebtedness, written verification of the  debt or a copy of the judgment will be provided to you.   30.   This statement did not accurately state COLE’s rights under the FDCPA, and was  misleading and deceptive, because COLE was entitled to dispute the debt “within thirty days  after receipt” of the Letter, not within 30 days of the date of the Letter. 15 U.S.C. § 1692g(a)(3).   31.   The statement also did not accurately state COLE’s rights under the FDCPA, and  was misleading and deceptive, because it failed to make clear that COLE was entitled to lodge a  dispute even if she did not dispute the entire debt but rather “any portion thereof”. 15 U.S.C §  1692g(a)(3).   32.   The statement further did not accurately state COLE’s rights under the FDCPA,  and was misleading and deceptive, because it failed to clarify that, if COLE did not dispute the  Debt, MENN, and only MENN, was entitled to assume it to be valid. 15 U.S.C. § 1692g(a)(3).   34.   This statement did not accurately state COLE’s rights under the FDCPA, and was  misleading and deceptive, because it failed to make clear that COLE had thirty days after receipt  of the Letter, not thirty days from the date of the Letter, to dispute the debt in writing. 15 U.S.C.  § 1692g(a)(4).   35.   The statement also did not accurately state COLE’s rights under the FDCPA, and  was misleading and deceptive, because it failed to make clear that COLE could send a written  dispute even if she did not dispute the entire debt but rather “any portion thereof”. 15 U.S.C §  1692g(a)(4).   36.   On the second page of the Letter, MENN stated in relevant part:   4. Attorney William P. McKinley of Menn Law Firm, Ltd. will  provide the name and the address of the original creditor if  different from the creditor named herein if such is requested by  the Debtor within thirty (30) days of the date hereof.  However,  to the best of the undersigned’s knowledge, the original  creditor and Creditor are one and the same. i.e. Exterior Homes  49.   MENN’s conduct is consistent with its policies and practices when attempting to  collect debts from consumers. Consequently, this action is brought by COLE, both individually  and on behalf of all other persons similarly situated, pursuant to Rule 23 of the Federal Rules of  Civil Procedure.   50.   Plaintiff seeks to certify a class pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3).   51.   Class Definition. The Class consists of: All natural persons to whom Defendant  mailed a written communication in the form of Exhibit A to an address in the State of Wisconsin  during the Class Period which begins on April 12, 2018 and ends on May 3, 2019.   52.   The identities of the Class members are readily ascertainable from MENN’s  business records or those entities on whose behalf MENN attempted to collect debts.   53.   Class Claims. The Class claims include all claims each Class member may have  for a violation of the FDCPA arising from Defendant having mailed a written communication in  the form of Exhibit A to such Class member.   54.   This action has been brought, and may properly be maintained, as a class action  pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure because there is a  well-defined community interest in the litigation:   56.   Common Questions Predominate. Common questions of law and fact exist as to  all members of the Class and those questions predominate over any questions or issues involving  only individual class members because such questions and issues concern the same conduct by  MENN with respect to each Class member.   57.   Typicality. Plaintiff’s claims are typical of those of the Class because those claims  arise from a common course of conduct engaged in by MENN.   58.   Adequacy. Plaintiff will fairly and adequately protect the interests of the Class  members insofar as Plaintiff has no interest adverse to the Class members. Moreover, Plaintiff is  committed to vigorously litigating this matter and has retained counsel experienced in handling  consumer lawsuits, complex legal issues, and class actions. Neither Plaintiff nor her counsel have  any interests which might cause them not to vigorously pursue the instant class action lawsuit.   59.   Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil  Procedure is appropriate in that the questions of law and fact common to the Class members  predominate over any questions affecting an individual member, and a class action is superior to  other available methods for the fair and efficient adjudication of the controversy.   60.   Based on discovery and further investigation (including, but not limited to,  disclosure by MENN of class size and net worth), Plaintiff may, in addition to moving for class  certification using modified Class definitions, Class claims, or Class periods, seek class  certification only as to particular issues as permitted under Fed. R. Civ. P. 23(c)(4).  VI.  61.   The factual allegations in the preceding paragraphs are realleged and incorporated  by reference.   63.   The Debt is a “debt” as defined by 15 U.S.C. §1692a(5).   64.   COLE is a “consumer” as defined by 15 U.S.C. § 1692a(3).   65.   The use and mailing of Exhibit A by MENN in an attempt to collect the Debt  violated the FDCPA in one or more following ways:  (a)  Using a false, deceptive, or misleading representation or means in  violation of 15 U.S.C. § 1692e;  (b)  Making the false representation or creating the false implication that any  individual is an attorney or that any communication is from an attorney in  violation of 15 U.S.C. § 1692e(3);   (c)  The use of any false representation or deceptive means to collect or  attempt to collect any debt or to obtain information concerning a  consumer, in violation of 15 U.S.C. § 1692e(10); and  (d)  Failing to provide a written notice containing accurate information  required under 15 U.S.C. §§ 1692g(a)(2)-(5).   PRACTICES ACT  