11.  This Action is properly maintained as a statewide class action. The Class consists  of:   All New Jersey consumers who were sent collection letters and/or notices  from the Defendant that contained at least one of the alleged violations arising  from the Defendant's violations of 15 U.S.C. § 1692 et seq.   The Class period begins one year to the filing of this Action.   13.  Sometime prior to June 5, 2012, Plaintiff allegedly incurred a financial obligation  to Home Depot.   14.  The Home Depot obligation arose out of a transaction in which money, property,  insurance or services, which are the subject of the transaction, are primarily for personal, family  or household purposes.    15.  At sometime prior to June 5, 2012, the Home Depot obligation was assigned to  Arches Financial, LLC.   16.  At the time the Arches Financial, LLC received assignment of the Home Depot  obligation, said obligation was in default.   17.  At some time prior to June 5, 2012, Arches Financial, LLC, assigned said  obligation to FNCB for the purpose of collection.   18.   FNCB contends that the alleged obligation is in default.   19.  The alleged obligation is a “debt” as defined by 15 U.S.C.§ 1692a(5).   20.  Plaintiff is at all times relevant to this lawsuit, a “consumer” as that term is  defined by 15 U.S.C. §1692a(3).   21.  FCNB 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.   23.   On or about June 5, 2012, FNCB caused to be delivered to Plaintiff a collection  letter addressed to Plaintiff. A copy of said letter is annexed hereto as Exhibit A.   24.  Said letter was sent or caused to be sent by persons employed by FNCB as a “debt  collector” as defined by 15 U.S.C. §1692a(6).   25.  Said letter was sent to Plaintiff in connection with the collection of a “debt” as  defined by 15 U.S.C.§1692a(5).   26.  Said letter is a “communication” as defined by 15 U.S.C. §1692a(2).   27.   Upon receipt, Plaintiff read said letter.    28.  On information and belief, said letter is a computer – generated form letter, that is  prepared for FNCB and sent to consumers from whom it is attempting to collect a debt.   29.  Said letter stated in part, "Our client ARCHES FINANCIAL, LLC is offering you  a settlement of $655.11 in 6 payments over 6 months starting on 06/26/12. (21 days)".   30.  Said letter further stated, "Payments may not be more than 30 days apart or this  settlement may be cancelled.  Please send in the payments along with the payment stub to the  address listed on the coupon."   31.  Said letter contained six detachable coupons each with the following "DUE  DATE" and "PAYMENT AMT."  1 of 6 06/26/12  $109.19  2 of 6 07/26/12  $109.19  3 of 6 08/25/12  $109.19  4 of 6  09/24/12  $109.19  5 of 6 10/24/12  $109.19  6 of 6 11/23/12  $109.19  (Exhibit A).   33.  Said letter also states that Plaintiff may pay the alleged debt by credit card, but  FNCB charges a transaction fee for doing so:  Payment by Credit Cards - Transaction Fees  MasterCard and Visa: $5.00 per $150.00  (Exhibit A).   34.  Said letter did not state the Transaction Fee should Plaintiff choose to pay the  alleged debt with a Discovery Card.   35.  The transaction fee sought by FNCB exceeds any service charge FNCB incurs  from its credit card processor or vendor.   38.  Plaintiff repeats the allegations contained in paragraphs 1 through 37 as if the  same were set forth at length.    INC.; and JOHN DOES 1-25.                                        Defendant(s).  Plaintiff, Lenore John, on behalf of herself and all others similarly situated  (hereinafter “Plaintiff”) by and through her undersigned attorney, alleges against the above- named Defendant, First National Collection Bureau, Inc. (hereinafter “FNCB”); and John Does  1-25, collectively (“Defendants”) their employees, agents, and successors the following:  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. § 1692 et seq.  