10.  Defendant alleges Plaintiff owes a debt (“the Debt”).     11.  The Debt was primarily for personal, family or household purposes and is  therefore a “debt” as defined by 15 U.S.C. § 1692a(5).   12.  Sometime after the incurrence of the Debt, Plaintiff fell behind on payments  owed.    13.  Thereafter, at an exact time known only to Defendant, the Debt was assigned or  otherwise transferred to Defendant for collection.    14.  In its efforts to collect the debt, Defendant contacted Plaintiff by letter (“the  Letter”) dated June 13, 2017. (“Exhibit 1.”)    15.  The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).    16.  15 U.S.C. § 1692e prohibits a debt collector from using any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   17.  While § 1692e specifically prohibits certain practices, the list is non-exhaustive,  and does not preclude a claim of falsity or deception based on any non-enumerated practice.   18.  The question of whether a collection letter is deceptive is determined from the  perspective of the “least sophisticated consumer.”    19.  A collection letter is deceptive under 15 U.S.C. § 1692e if it can reasonably be  read by the least sophisticated consumer to have two or more meanings, one of which is  inaccurate.    20.  A collection letter is also deceptive under 15 U.S.C. § 1692e if it is reasonably  3  48.  Plaintiff brings this action individually and as a class action on behalf of all  persons similarly situated in the State of New York from whom Defendant attempted to collect a  consumer debt using a collection letter that fails to identify any entity as “creditor,” “original  creditor,” “current creditor,” “account owner,” or “creditor to whom the debt is owed,” but only  includes “Re: [name of entity],” from one year before the date of this Complaint to the present.    49.  This action seeks a finding that Defendant’s conduct violates the FDCPA, and  asks that the Court award damages as authorized by 15 U.S.C. § 1692k.   50.  Defendant regularly engages in debt collection.   51.  The Class consists of more than 35 persons from whom Defendant attempted to  collect delinquent consumer debts using a collection letter that fails to identify any entity as  “creditor,” “original creditor,” “current creditor,” “account owner,” or “creditor to whom the  debt is owed,” but only includes “Re: [name of entity],”.   52.  Plaintiff’s claims are typical of the claims of the Class.  Common questions of law  5 