14.  On or around August 19, 2013, Lowery mailed a debt collection letter to Plaintiff  regarding an alleged debt allegedly owed to CACH and allegedly previously owed to “Bank of  America, N.A.” A copy of this letter is attached to this complaint as Exhibit A.   15.  The alleged debt identified in Exhibit A was for an alleged personal credit card,  used only for personal, family or household purposes.   16.  Upon information and belief, Exhibit A is a form letter, generated by a computer,  and with the information specific to Plaintiff inserted by the computer.   17.  Exhibit A contains the following text:  Exhibit A.   18.  The letter purports to offer a “one-time settlement” of Plaintiff’s account.   19.  Exhibit A falsely states or implies that the settlement offer is valid “for a limited  time only.”   21.  Such false statements are material false statements, as they impart in the  unsophisticated consumer, a false belief that he or she must hurry to take advantage of a limited- time opportunity, when in reality, there is no such time limit.   22.  Further, the “limited time offer” language is merely a tactic to get consumers to  pay anything on old debts that CACH purchased for pennies on the dollar, especially when an  alleged debt has been sold to a debt buyer like CACH. See FTC, The Structure and Practices of  the Debt Buying Industry, January, 2013 at 23 (available at http://www.ftc.gov/sites/default/files/  documents/reports/structure-and-practices-debt-buying-industry/debtbuyingreport.pdf (Average  purchase price for consumer credit card debt is 4.0 cents on the dollar).   23.  The Seventh Circuit has established “safe harbor” language regarding settlement  offers in collection letters:  As in previous cases in which we have created safe-harbor language for  use in cases under the Fair Debt Collection Practices Act, we think the  present concern can be adequately addressed yet the unsophisticated  consumer still be protected against receiving a false impression of his  options by the debt collector's including with the offer the following  language: “We are not obligated to renew this offer.” The word  “obligated” is strong and even the unsophisticated consumer will realize  that there is a renewal possibility but that it is not assured.  Evory v. RJM Acquisitions Funding L.L.C., 505 F.3d 769, 775-76 (7th Cir. 2007).    24.  Defendant did not use the safe harbor language in Exhibit A.   25.  Upon information and belief, the deadline in Exhibit A to respond to the  settlement offer is a sham. There is no actual deadline. The sole purpose of the purported  deadline is to impart in the consumer a false sense of urgency.  27.  Exhibit A includes false statements to the effect that the settlement offer is only  available for a limited time.   28.  Upon information and belief, Lowery and CACH would settle Plaintiff’s and class  members’ debts at any time, regardless of the supposed deadline.   29.  15 U.S.C. § 1692e(10) specifically prohibits the “use of any false representation  or deceptive means to collect or attempt to collect any debt.”   30.  15 U.S.C. § 1692f generally prohibits “unfair or unconscionable means to collect  or attempt to collect any debt.”   31.  Lowery violated 15 U.S.C. §§ 1692e, 1692e(10) and 1692f.  32.  Plaintiff brings this action on behalf of a Class, consisting of (a) all natural  persons in the State of Wisconsin (b) who were sent a collection letter in the form represented by  Exhibit A, (c) seeking to collect a debt for personal, family or household purposes, (d) on or after  June 3, 2013, (e) that was not returned by the postal service.   33.  The Class is so numerous that joinder is impracticable.  On information and  belief, there are more than 50 members of the Class.   34.  There are questions of law and fact common to the members of the class, which  common questions predominate over any questions that affect only individual class members.   The predominant common question is whether the Defendants complied with 15 U.S.C. §§  1692e and 1692f.   36.  Plaintiff will fairly and adequately represent the interests of the Class members.  Plaintiff has retained counsel experienced in consumer credit and debt collection abuse cases.   37.  A class action is superior to other alternative methods of adjudicating this dispute.    Individual cases are not economically feasible. 