11.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   13.  The identities of all class members and sub-class members are readily ascertainable  from the records of Defendant and those companies and entities on whose behalf they attempt  to collect and/or have purchased debts.   14.  Excluded from the Plaintiff Class and sub-class are the Defendant and all officers,  members, partners, managers, directors and employees of the Defendant and their respective  immediate families, and legal counsel for all parties to this action, and all members of their  immediate families.    15.  There are questions of law and fact common to the Plaintiff Class and sub-class,  which common issues predominate over any issues involving only individual class members.  The principal issue is whether the Defendants' written communications to consumers, in the  forms attached as Exhibit A, violate 15 U.S.C. § l692e.   16.  The Plaintiff’s claims are typical of the class members and sub-class members, as all  are based upon the same facts and legal theories. The Plaintiff will fairly and adequately protect  the interests of the Plaintiff Class and sub-class defined in this complaint. The Plaintiff has  retained counsel with experience in handling consumer lawsuits, complex legal issues, and class  actions, and neither the Plaintiff nor his attorneys have any interests, which might cause them  not to vigorously pursue this action.   18.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Class and sub-class 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.   19.  Depending on the outcome of further investigation and discovery, Plaintiff may, at  the time of class certification motion, seek to certify a class(es) only as to particular issues  pursuant to Fed. R. Civ. P. 23(c)(4).  20.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   21.  Some time prior to January 8, 2021, an obligation was allegedly incurred to a  creditor, Discover Bank.     22.  Upon information and belief, Discover Bank received a judgment related to the  underlying debt.    23.  Upon information and belief, Discover Bank retained Defendant PFW, a Law Firm,  to act as their agent in collecting the subject debt from the Plaintiff.    24.  The subject debt arose out of a credit card debt. The subject debt was incurred by  Plaintiff solely for personal, household or family purposes.   26.  The subject obligation is consumer-related, and therefore a "debt" as defined by 15  U.S.C.§ 1692a (5).   27.  Defendant was contracted for the purpose of collecting the subject debt on behalf of  Discover Bank. Therefore, Defendant is a “debt collector” as defined by 15 U.S.C.§ 1692a (6).  Violations – January 8, 2021 Collection Letter   28.  On or about January 8, 2021, Defendant sent the Plaintiff a collection letter (the  “Letter”) regarding the alleged debt owed to Discover Bank. (See Letter at Exhibit A.)   29.  The letter states a balance of $11,636.66   30.  Defendant further makes settlement offers relating to the Judgment connected with  the referenced balance.    31.  However, Defendant failed to advise the Plaintiff that since this debt has become a  judgment, the total amount due will continually increase by the accrual of interest, which began  from the date of the entry of judgment and will continue until the judgment is paid.    32.  As a result, the Plaintiff incurred an informational injury as Defendant misstated the  balance due by failing to include the fact that interest would continue to accrue from the date of  the entry of judgment.    33.  As a result of Defendant’s deceptive, misleading and unfair debt collection practices,  Plaintiff has been damaged.  35.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   36.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   37.  Defendant violated §1692e:   a. As the letter falsely represents the true amount of the debt in violation of §1692e  (2); and  b. As the letter falsely represents the character and legal status of the debt in  violation of §1692e(2)(A); and  c. By making a false and misleading representation in violation of §1692e(10).   38.  By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  