10.  Defendant is a business entity engaged in the business of collecting consumer debts.   11.  Defendant regularly collects or attempts to collect, directly or indirectly, debts  owed or due or asserted to be owed or due another.   26.  This action is brought on behalf of the following “FDCPA Class.”     27.  The “FDCPA Class” consists of: (1) all persons with Florida addresses (2) who  were mailed a letter (3) from Defendant (4) that attempt to collect a time-barred consumer debt (5)  during the twelve [12] months preceding the filing of this Complaint.    28.  Plaintiff alleges, on information and belief, each class is so numerous that joinder  of all members is impracticable because Defendant has dispatched thousands of identical letters to  addresses in Florida which unlawfully and/or otherwise deceptively attempt to collect time-barred  consumer debts from Florida consumers.    29.  Common questions of law and fact exist as to the proposed class and otherwise  predominate over any issues involving only individual class members.   39.  On behalf of the FDCPA Class, Plaintiff incorporates by reference paragraphs 1-38  as though fully set forth herein.     40.  Defendant violated § 1692e, § 1692e(2)(A), § 1692e(5), § 1692e(10), and § 1692f  of the FDCPA because the Collection Letter Defendant dispatched to Plaintiff, in light of the least  sophisticated consumer standard, was a deceptive, misleading, unfair, and unconscionable attempt  to collect the time-barred debt from the least sophisticated consumer.   5.1  8.  The debt at issue (the “Consumer Debt”) is a financial obligation Plaintiff incurred  primarily for personal, family, or household purposes.    9.  Defendant is a business entity engaged in the business of soliciting consumer debts  for collection.   VIOLATION OF 15 U.S.C. § 1692e, e(2)(A), e(5), e(10), & § 1692f  