10.  In pursuit of said debt, Defendant sent Plaintiff some collection letters.    12.  Plaintiff paid the bill by credit card on or about September 2016.   13.  However, while charging Plaintiff’s card, Defendant charged Plaintiff an  additional service fee of $4.95. Exhibit A.   14.  Service fees are incidental to the principal obligation.    15.  Seeking to collect an incidental service fee in connection with the collection  of a debt where underlying state law does not provide for such a fee, or where the  underlying contract does not expressly permit such fees, is a violation of the FDCPA.   16.  Upon information and belief, neither Arizona law nor the contract between  Plaintiff and the original creditor expressly authorized a $4.95 service charge as  Defendant charged here.   17.  Credit card service fees typically vary depending on the size of the  transaction and the credit card processor. Typically, a credit card service fee structure has  a minimum fee per transaction (usually less than 50 cents), in addition to a percentage of  the transaction (usually less than 1 percent).   18.  Upon information and belief, Defendant’s set $4.95 rate applies to every  transaction, and is not specifically tailored to the amount of Plaintiff’s debt.   19.  Considering that credit card service fees sought are a percentage of the  debt, and the debt here is in the amount of $188.18, the consistent $4.95 fee likely does  not reflect the true processing or service cost.     21.  Alternatively, upon information and belief, Defendant receives a portion of  the excess amount as a kickback from the processor for providing the processor with  extra revenue.   22.  By falsely implying that Defendant is legally allowed to seek a $4.95  processing or service fee, and by collecting an illegal service fee, Defendant’s collection  efforts violate the FDCPA.   23.  After Plaintiff made his payment, Defendant emailed him a receipt. The  email constituted a communication in connection with the collection of the debt.  However, nowhere within the email did Defendant inform Plaintiff that it is a debt  collector, as the FDCPA requires. Accordingly, said email violates the FDCPA.    24.  Notwithstanding the above, Defendant’s collection letters also violated the  FDCPA. Exhibit B. In its April 9, 2016 letter to Plaintiff, Defendant merely informed  Plaintiff of the amount of the debt. The letter never provided any information to Plaintiff  stating that in the event Plaintiff chose to pay via a credit card, he would be incurring an  additional fee. By failing to provide this crucial information to Plaintiff, Plaintiff was  misled into believing that he had no option but to pay the additional fee. Thus,  Defendant’s letters also violate the FDCPA.    26.  Plaintiff brings this as a class action pursuant to Fed. R. Civ. P. 23.   27.  Plaintiff seeks certification of the following classes, initially defined as  follows:  Service Fee Class: All consumers within the United States that have  made payment to Defendant concerning debts used primarily for  personal, household, or family purposes within one year prior to filing  of this complaint wherein Defendant charged the consumer an  impermissible service fee.  Fee Omission Class: All consumers within the United States that have  received collection letters from Defendant, concerning debts used  primarily for personal, household, or family purposes within one year  prior to filing of this complaint which fail to inform the consumer of  the different payment options and the subsequent fees incurred for  specific payment options.    28.  Excluded from the Class is Defendant herein, and any person, firm, trust,  corporation, or other entity related to or affiliated with the defendant, including, without  limitation, persons who are officers, directors, employees, associates or partners of  Defendant.    Numerosity   30.  The exact number and identities of the Class members are unknown at this  time and can only be ascertained through discovery. Identification of the Class members  is a matter capable of ministerial determination from Defendant’s records.   Common Questions of Law and Fact   31.  There are questions of law and fact common to the class that predominates  over any questions affecting only individual Class members. These common questions of  law and fact include, without limitation: (i) Whether Defendant violated the FDCPA; (ii)  Whether Plaintiff and the Class have been injured by Defendant's conduct; (iii) Whether  Plaintiff and the Class have sustained damages and are entitled to restitution as a result of  Defendant's wrongdoing and, if so, what is the proper measure and appropriate statutory  formula to be applied in determining such damages and restitution; (iv) Whether Plaintiff  and the Class are entitled to declaratory and/or injunctive relief; and, (v) Whether  Defendant’s conduct was willful.   Typicality   32.  Plaintiff's claims are typical of the claims of the Class, and Plaintiff has no  interests adverse or antagonistic to the interests of other members of the Class.  Protecting the Interests of the Class Members   34.  A class action is superior to other methods for the fair and efficient  adjudication of the claims herein asserted.   35.  The members of the Class are generally unsophisticated individuals, whose  rights will not be vindicated in the absence of a class action.   36.  Prosecution of separate actions by individual members of the Class would  create the risk of inconsistent or varying adjudications resulting in the establishment of  inconsistent or varying standards for the parties.   37.  A class action will permit a large number of similarly situated persons to  prosecute their common claims in a single forum simultaneously, efficiently, and without  the duplication of effort and expense that numerous individual actions would engender.  Class treatment also will 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.   38.  Absent a class action, the Class members will continue to suffer losses  borne from Defendant’s breaches of Class members’ statutorily protected rights as well  as monetary damages, thus allowing and enabling: (a) Defendants conduct to proceed  and; (b) Defendants to further enjoy the benefit of its ill-gotten gains.   40.  Plaintiff repeats, realleges, and reincorporates the allegations contained in  the paragraphs above and incorporates them as if set forth specifically herein.   41.  Defendant’s illegal conduct has violated the following sections of the  7.  On or about June 2013, Plaintiff incurred a medical debt.   8.  The debt owed was $188.18.   9.  Medical debt has long been considered debt for personal, family, and  household use.   The Class   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692 et seq   