11.  Plaintiffs bring 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 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.   14.  Excluded from the Plaintiff Class are the Defendants and all officer, members,  partners, managers, directors and employees of the Defendants 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, 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. §§ 1692e.   16.  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 her attorneys have any interests, which might cause them not to vigorously pursue this  action.   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 February 24, 2020, an obligation was allegedly incurred to  creditor PSEG-NJ.   22.  The PSEG-NJ obligation arose out of transactions incurred primarily for personal,  family or household purposes.    23.  The alleged PSEG-NJ obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   24.  PSEG-NJ is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   25.  Defendant ICS contracted with PSEG-NJ to collect the alleged debt.  Violation – February 24, 2020 Collection Letter   26.  On or about February 24, 2020, Defendant ICS sent the Plaintiff an initial collection  letter (the “Letter”) regarding the alleged debt owed. See a true and correct copy of the Letter  attached at Exhibit A.   28.  The letter states that the account information is scheduled to be reported in “your  creditor’s name,” which according to the Letter is PSEG-NJ.   29.  However, upon information and belief, Defendant ICS reports the debt in their own  name to the national credit reporting agencies.  Therefore, the letter is deceptive by stating that  the account will be reported in the name of the original creditor.   30.  In addition, the letter states “I.C. System” will not submit the account information  until the expiration of the time period described below, implying that after said “expiration of  the time period,” Defendant ICS would be doing the credit reporting.    31.  In the alternative, if both Defendant ICS and the original creditor are both reporting  to the national reporting agencies, it would constitute deceptive double-reporting.    32.  It is deceptive for two companies will report to the credit reporting agencies on the  same debt.   33.  As a result of Defendant's deceptive, misleading and unfair debt collection practices,  Plaintiff has been damaged.  34.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   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 it is open to more than one reasonable interpretation, at least one of  which is inaccurate.  b. By making a false and misleading representation in violation of §1692e(10).   38.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, and Plaintiff is entitled to an award of  actual damages, statutory damages, costs and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  