10.  Plaintiff Morgan entered into one or more consumer transactions with “ATI  Physical Therapy” (“ATI”) or an affiliate or predecessor corporation.    11.  Each consumer transaction was incurred for personal medical services.   12.  Further, each consumer transaction involved agreements to render services and  defer payment. Plaintiff Morgan was not expected to pay at the time medical services were  rendered, but was billed at a later date.   13.  On or about October 21, 2016, Transworld mailed a debt collection letter to  Plaintiff regarding an alleged debt owed to ATI. A copy of this letter is attached as Exhibit A.   15.  Exhibit A is a form letter that does not require an envelope because it is a “folded  self-mailer.”  See Sears, Roebuck & Co. v. United States Postal Serv., 134 F. Supp. 3d 365, 370  (D.D.C. Sept. 30, 2015) (“a folded self-mailer is formed from a single sheet of cardstock that is  folded once on the right side (the leading edge), addressed on the front, and sealed to make a  letter-sized mailpiece.”).   16.  Folded self-mailers like Exhibit A are eligible for special low postage rates  because of the ease of automated processing.  Sears, 134 F. Supp. 3d at 371.   17.  Folded self-mailers like Exhibit A usually use a gumming agent like glue to seal  the mailer, which “prevent[s] the open edges from fanning out and jamming high-speed  processing equipment.” Sears, 134 F. Supp. 3d at 371.   18.  Where a self-folded mailer is used for a debt collection letter, the letter also must  remain sealed to prevents disclosure of the debt and comply with the FDCPA.  See 15 U.S.C. §  1692c(b).   19.  Exhibit A lists a “CURRENT BALANCE DUE.”   20.  The amount of the “CURRENT BALANCE DUE” and other information specific  to the alleged debt in question were disclosed in the location on the self-folded mailer where the  gumming agent was used to seal the mailer.   21.  As a result of the coincident placement of this information and the gumming  agent within Exhibit A, it became impossible to determine the amount that was due once the  letter was opened because this information was attached to the gumming agent when it became  separated from the face of the letter.   23.  Sending letters that make it impossible for the debtor to determine the amount of  the debt and other critical information specific to the debt is communication in a manner that can  reasonably be expected to harass the customer.   24.  The unsophisticated consumer would be confused by Exhibit A.   25.  Plaintiff Morgan had to spend time and money investigating Exhibit A.   26.  Plaintiff Morgan had to take time to obtain and meet with counsel, including  traveling to counsel’s office by car and its related expenses, including but not limited to the cost  of gasoline and mileage, to advise Plaintiff on the consequences of Exhibit A.  Facts Relating to Plaintiff Al   27.  On or about February 13, 2017, Transworld mailed a debt collection letter to  Plaintiff Al regarding an alleged debt owed to “ATI PHYSICAL THERAPY” (“ATI”).  A copy  of this letter is attached to this Complaint as Exhibit B.   28.  Each consumer transaction was for personal medical services.   29.  Further, each consumer transaction involved agreements to render services and  defer payment.  PLaintiff Al was never expected to pay at the time medical services were  rendered.  ATI mailed bills to Plaintiff Al at a later date.   30.  Upon information and belief, Exhibit B is a form letter, generated by computer,  and with the information specific to Plaintiff Al inserted by computer.   31.  Upon information and belief, Exhibit B is a form debt collection letter used by  Transworld to attempt to collect alleged debts.   33.  Exhibit B also contains three payment options that purport to offer Plaintiff Al the  opportunity to “pay the debt in full.”   34.  Exhibit B explains the payment options as follows:  Exhibit B.   35.  However, Exhibit B also states:  Exhibit B.   36.  The representation in Exhibit B that the payment options will “resolve” the  account and “pay the account in full” are false, misleading, and confusing to the unsophisticated  consumer as the language above states that interest or other charges may be periodically added to  the account balance.   37.  Thus, it is unclear whether the “consecutive monthly payment” amounts listed in  Options 1, 2, and 3 will actually resolve the alleged debt.   39.  Exhibit B fails to state the terms of the payment options in a non-confusing  manner.   40.  Neither the unsophisticated consumer nor the “competent attorney” could  determine from Exhibit B whether the payment options would resolve the alleged debt.   41.  Exhibit B is ambiguous and capable of at least two meanings.  It is unclear  whether completing the “paid in full” payment plans, which will not add up to the actual amount  of the debt if interest and other charges are added, would be treated as settlements or as a partial  payment against Plaintiff’s full balance.  Exhibit B.   42.  Transworld’s language leaves open the possibility that the consumer will make  the monthly payments, only to have the entire payment applied to the actual “full balance”  resulting in the consumer still owing a portion of the debt.   43.  Treating the payments as being short of the actual full amount of the debt would  permit ATI or third-party debt collectors hired by ATI to continue to try to collect on the same  debt.   44.  An alleged debtor could pay the monthly payments and not know whether he or  she has resolved the alleged account. Exhibit B. The language is confusing to the unsophisticated  consumer.   45.  Moreover, the unsophisticated consumer could not determine whether timely  making all payments under the proposed plan would result in ATI representing to credit  reporting agencies that the account is paid in full, settled in full, or partially paid with  outstanding balance.   47.  The consequences of misleading a consumer with respect to settling a debt are  material and misleading statements are material false statements under the FDCPA.   48.  An account reported to a credit reporting agency as “settled in full” has a greater  negative effect on a consumer’s credit score than an account reported as “paid in full.”  Thus,  consumers who are able to pay off a balance may wish to pay the entire amount instead of  “settle” for pennies less than the full amount of the debt in order to effect an improvement in  their credit score.   49.  The unsophisticated consumer would be confused by Exhibit B.   50.  Plaintiff had to spend time and money investigating Exhibit B.   51.  Plaintiff had to take time to obtain and meet with counsel, including traveling to  counsel’s office by car and its related expenses, including but not limited to the cost of gasoline  and mileage, to advise Plaintiff on the consequences of Exhibit B.  73.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   74.  Count I is brought on behalf of Plaintiff Morgan.   75.  In Exhibit A, Defendant placed critical information specific to the alleged debt in  a location where that information would become attached to the self-folded mailer’s gumming  agent, making it impossible for the debtor to read that information once the letter was opened.   76.  Defendant placed this information in this location with the purpose of inducing  alleged debtors to contact Defendant, whereupon Defendant would engage in high-pressure  tactics in order to induce alleged debtors to pay debts that Defendant was collecting, possibly at  the expense of payment to other debt collectors who were not engaging in such deceptive  conduct.   77.  Defendant violated 15 U.S.C. §§ 1692e, 1692e(2)(A), 1692e(10), and 1692f.  78.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   79.  Count II is brought on behalf of Plaintiff Al.   81.  If a consumer chooses to mail in payments in an attempt to take advantage of one  of the “Paid in Full” monthly installment plans listed on the letter, Defendant could, under one  interpretation of Exhibit B, apply the payments toward the actual “full balance” instead of  settling the debt.   82.  It is unclear whether the creditor or Transworld would continue to collect any  interest or other charges added to the debt if the consumer paid the full amount of a “paid in full”  payment plan.   83.  It is also unclear whether completing the “paid in full” payment plans, which will  not add up to the actual amount of the debt if interest and other charges are added, would be  treated as “settlements for less than the full balance” for credit reporting purposes because the  payments would be short of the actual balance.   84.  Exhibit B misleads the unsophisticated consumer and encourages payments that  do not actually settle the alleged debt, allowing ATI or third-party debt collectors hired by ATI  to continue collecting the remaining balance.   85.  Exhibit B also confuses the consumer as to whether an account would be reported  to credit reporting agencies as “settled in full” or “paid in full” after completing of the payment  plans, as the payments are short of the balances.   86.  Defendant violated 15 U.S.C. §§ 1692e, 1692e(2)(A), 1692e(10), and 1692f.  87.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   89.  The statements in Exhibit B that Transworld will consider the debt paid in full if  Plaintiff Al completes one of the monthly payment plans, which fail to add up to the full amount  of the debt after the addition of interest and other charges, is inherently or apparently  contradictory.   90.  The unsophisticated consumer would have no idea how a debt could be paid in  full when the full balance was not actually paid.   91.  The language is intended to make the consumer call Transworld, subjecting him  or her to additional collection efforts and high-pressure collection tactics.   92.  Defendant violated 15 U.S.C. §§ 1692e, 1692e(10), and 1692f.   93.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   94.  Count IV is brought on behalf of Plaintiff Morgan.   95.  In Exhibit A, Defendant placed critical information specific to the alleged debt in  a location where that information would become attached to the self-folded mailer’s gumming  agent, making it impossible for the debtor to read that information once the letter was opened.   96.  Defendant placed this information in this location with the purpose of inducing  alleged debtors to contact Defendant, whereupon Defendant would engage in high-pressure  tactics in order to induce alleged debtors to pay debts that Defendant was collecting, possibly at  the expense of payment to other debt collectors who were not engaging in such deceptive  conduct.   98.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   99.  Count V is brought on behalf of Plaintiff Morgan.  100.  In Exhibit A, Defendant placed critical information specific to the alleged debt in  a location where that information would become attached to the self-folded mailer’s gumming  agent, making it impossible for the debtor to read that information once the letter was opened.  101.  Defendant placed this information in this location with the purpose of inducing  alleged debtors to contact Defendant, whereupon Defendant would engage in high-pressure  tactics in order to induce alleged debtors to pay debts that Defendant was collecting, possibly at  the expense of payment to other debt collectors who were not engaging in such deceptive  conduct.  102.  Defendant violated Wis. Stat. § 426.110(2)(c).  Facts Relating to Plaintiff Morgan  