1. The amount of the debt;   10.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ. P.  23(a) and 23(b)(3).   11.  The Class consists of:   a.  all individuals with addresses in the State of New York;  b.  to whom Defendant Harris sent an initial collection letter;  c.  attempting to collect a consumer debt;  d.  providing multiple addresses;  e.  without identifying the correct address to which to send a dispute; and  f.  which letter was sent on or after a date one (1) year prior to the filing of this action  and on or before a date twenty-one (21) days after the filing of this action.   12.  The identities of all class members are readily ascertainable from the records of  Defendants and those companies and entities on whose behalf they attempt to collect and/or have  purchased debts.   13.  Excluded from the Plaintiff Class is the Defendant and all officers, members, partners,  managers, directors and employees of the Defendant and its respective immediate families, and legal  counsel for all parties to this action, and all members of their immediate families.    14.  There are questions of law and fact common to the Plaintiff Class, which common issues  predominate over any issues involving only individual class members. The principal issue is whether  the Defendant’s written communications to consumers, in the forms attached as Exhibit A, violate  15 U.S.C. §§ 1692e, 1692f, and 1692g.  4   15.  The Plaintiff’s claims are typical of the 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 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.   16.  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:  a. Numerosity: The Plaintiff is informed and believes, and on that basis alleges,  that the Plaintiff Class defined above is so numerous that joinder of all members  would be impractical.  b. Common Questions Predominate: Common questions of law and fact exist as  to all members of the Plaintiff Class and those questions predominance over any  questions or 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. §§ 1692e, 1692f, and 1692g.  c. Typicality: The Plaintiff’s claims are typical of the claims of the class members.  The Plaintiff and all members of the Plaintiff Class have claims arising out of the  Defendant’s common uniform course of conduct complained of herein.  d. Adequacy: The Plaintiff will fairly and adequately protect the interests of the  class members insofar as Plaintiff has no interests that are adverse to the absent  class members. The Plaintiff is committed to vigorously litigating this matter.  Plaintiff has also retained counsel experienced in handling consumer lawsuits,  5  complex legal issues, and class actions. Neither the Plaintiff nor her counsel have  any interests which might cause them not to vigorously pursue the instant class  action lawsuit.  e. Superiority: A class action is superior to the other available means for the fair  and efficient adjudication of this controversy because individual joinder of all  members would be impracticable. Class action treatment will permit a large  number of similarly situated persons to prosecute their common claims in a single  forum efficiently and without unnecessary duplication of effort and expense that  individual actions would engender.   17.  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  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.   18.  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).  19.  Plaintiff repeats the above allegations as if set forth here.   2. The name of the creditor to whom the debt is owed;   20.  Some time prior to December 4, 2020, Plaintiff allegedly incurred an obligation to  The Trustees of Columbia University in the City of New York (“Columbia”).   21.  The obligation arose out of a transaction involving a medical debt to Columbia in  which money, property, insurance or services, which are the subject of the transaction, were incurred  solely for personal purposes, specifically personal medical care.  6   22.  The alleged Columbia obligation is a "debt" as defined by 15 U.S.C.§ 1692a (5).   23.  Columbia is a "creditor" as defined by 15 U.S.C. § 1692a (4).   24.  Upon information and belief, Columbia contracted with the Defendant Harris to  collect the alleged debt. Therefore, Harris is a “debt collector” as defined by 15 U.S.C. § 1692a (6).   25.  Defendant Harris collects and attempts to collect debts incurred or alleged to have  been incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and internet.  Violation – December 4, 2020 Collection Letter   26.  On or about December 4, 2020, Defendant sent the Plaintiff an initial collection letter  regarding the alleged debt owed to Columbia.  See Letter attached as Exhibit A.   27.  The letter ostensibly provides the notices as required by 15 U.S.C. § 1692g regarding  disputing the debt.   28.  However, there are three addresses listed for Defendant in two different cities and  states:   a. 111 West Jackson Blvd, Suite 400, Chicago, IL, 60604  b. P.O. Box 21418, New York, NY 10087  c. P.O. Box 5462, Chicago, IL 60680   29.  None of the three addresses are specifically identified as the correct address to which  to send a dispute.   3. A statement that unless the consumer, within thirty days after  receipt of the notice, disputes the validity of the debt, or any  portion thereof, the debt will be assumed to be valid by the debt- collector;   30.  Plaintiff was therefore confused as to how to properly dispute the debt and exercise  her rights under § 1692g.   31.  Upon information and belief, disputes sent to one or more of these addresses will not  be honored by Defendant.  7   32.  Listing these incorrect addresses(es) misled Plaintiff into believing a proper dispute  can be sent there.   33.  Plaintiff was therefore unable to straightforwardly dispute the debt resulting in  wasted time.   34.  Plaintiff was therefore unable to evaluate her options of how to handle this debt.   35.  Because of this, Plaintiff expended time, money, and effort in determining the proper  course of action.   36.  These violations by Defendant were knowing, willful, negligent and/or intentional,  and Defendant did not maintain procedures reasonably adapted to avoid any such violations.   37.  Defendant’s collection efforts with respect to this alleged debt from Plaintiff caused  Plaintiff to suffer concrete and particularized harm, inter alia, because the FDCPA provides Plaintiff  with the legally protected right not to be misled or treated unfairly with respect to any action  regarding the collection of any consumer debt.   38.  Defendant’s deceptive, misleading and unfair representations with respect to its  collection efforts were material misrepresentations that affected and frustrated Plaintiff's ability to  intelligently respond to Defendant’s collection efforts because Plaintiff could not adequately  respond to Defendant’s demand for payment of this debt.   39.  Defendant’s actions created an appreciable risk to Plaintiff of being unable to  properly respond or handle Defendant’s debt collection.   4. A statement that the consumer notifies the debt collector in  writing within thirty-day period that the debt, or any portion  10  thereof, is disputed, the debt collector will obtain verification of  the debt or a copy of a judgment against the consumer and a copy  of such verification or judgment will be mailed to the consumer  by the debt collector; and   40.  Plaintiff was confused and misled to her detriment by the statements in the dunning  letter, and relied on the contents of the letter to her detriment.   41.  Plaintiff would have pursued a different course of action were it not for Defendant’s  statutory violations.  8   42.  As a result of Defendant’s deceptive, misleading and false debt collection practices,  Plaintiff has been damaged.  43.  Plaintiff repeats the above allegations as if set forth herein.   44.  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.   45.  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.   46.  Defendant violated said section by deceptively and/or misleadingly providing  multiple addresses and not identifying which one should be used to dispute the debt, in violation  of § 1692e (10).   47.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  48.  Plaintiff repeats the above allegations as if set forth herein.   49.  In the alternative, 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. § 1692f.   5. A statement that, upon the consumer’s written request within the  thirty-day period, the debt collector will provide the consumer  with the name and address of the original creditor, if different  from the current creditor.   50.  Pursuant to 15 U.S.C. § 1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.  9   51.  Defendant violated this section by unfairly providing multiple addresses and not  identifying which one to use for disputing a debt.   52.  By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant's  conduct violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  53.  Plaintiff repeats the above allegations as if set forth herein.   54.  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. § 1692g.   55.  Pursuant to 15 U.S.C. § 1692g:  Within five days after the initial communication with a consumer in  connection with the collection of any debt, a debt collector shall, unless the  following information is contained in the initial communication or the  consumer has paid the debt, send the consumer a written notice containing –   56.  Defendant violated this section by providing multiple addresses and not identifying  which one to use for disputing the debt, thereby failing to provide the proper notice required by  §1692g in an initial collection letter.   57.  By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant's  conduct violated Section 1692g 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. §1692g et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692f et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e et seq.  