10.  Upon information and belief, Exhibit A is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.   11.  Exhibit A is the first letter that Plaintiff received from Life Line regarding the  alleged debt referenced in Exhibit A.   12.  In Exhibit A, Life Line identifies itself as a debt collector:   14.  Exhibit A does not include the 15 U.S.C. § 1692g(a)(5) notice, which requires:  (5) a statement that, upon the consumer’s written request within the thirty- day period, the debt collector will provide the consumer with the name  and address of the original creditor, if different from the current creditor.  15 U.S.C. § 1692g(a)(5) (emphasis added).   15.  Exhibit A fails to inform the unsophisticated consumer that, in order to invoke his  or her right to require the debt collector to cease most collection activities until it provides the  name of the original creditor, the consumer must make the request in writing. 15 U.S.C. §  1692g(a)(5).   16.  By omitting the words “in writing,” Life Line did not effectively convey to the  consumer his FDCPA rights. See McCabe v. Crawford & Co., 272 F. Supp. 2d 736, 743 (N.D.  Ill. 2003); see also Desantis v. Computer Credit, Inc., 269 F.3d 159, 161 (2d Cir. 2001) (a “debt  collector violates the Act if it fails to convey the information required by the Act.”).   17.  Failure to provide the correct notice pursuant to 15 U.S.C. § 1692g(a)(5) is a  material violation of the FDCPA.   18.  The notice informs the consumer of his or her right to demand that the debt  collector provide the name of the original creditor, during which process many debt collection  activities must stop. 15 U.S.C. § 1692g(b).   19.  Further, as debts are generally freely assignable, and creditors frequently change  names and addresses, the § 1692g(a)(5) provides the consumer with a method of determining  whether, and to whom, he or she actually owes a particular debt.   21.  Plaintiff incorporates by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   22.  Life Line failed to include the required notice pursuant to 15 U.S.C. § 1692g(a)(5)  on Exhibit A.   23.  Life Line has thus failed to comply with the debt validation notice requirements  pursuant to 15 U.S.C. § 1692g(a).   24.  Exhibit A fails to inform the consumer that, in order to invoke his or her right to  obtain the name and address of the original creditor, the consumer must make the request in  writing. 15 U.S.C. § 1692g(a)(5).   25.  Failure to provide the 15 U.S.C. § 1692g(a)(5) notice is also a false representation  or deceptive means to collect a debt, in violation of 15 U.S.C. § 1692e(10).   26.  The Defendant has violated 15 U.S.C. §§ 1692g(a), 1692g(a)(5) and 1692e(10).  27.  Plaintiff brings this action on behalf of a Class, consisting of (a) all natural  persons in the State of Wisconsin (b) who were sent a collection letter in the form represented by  Exhibit A, (c) seeking to collect a debt for personal, family or household purposes, (d) on or after  October 12, 2014, (e) that was not returned by the postal service.   28.  The Class is so numerous that joinder is impracticable.  Upon information and  belief, there are more than 50 members of the Class.   30.  Plaintiff’s claims are typical of the claims of the Class members.  All are based on  the same factual and legal theories.   31.  Plaintiff will fairly and adequately represent the interests of the Class members.  Plaintiff has retained counsel experienced in consumer credit and debt collection abuse cases.   32.  A class action is superior to other alternative methods of adjudicating this dispute.    Individual cases are not economically feasible.  8.  On or about February 23, 2015, Life Line (under the name LifeQuest) mailed a  debt collection letter to Plaintiff regarding an alleged debt owed to “CITY-CUDAHY FIRE  DEPARTMENT.” Upon information and belief, this was the first letter Life Line sent Plaintiff  regarding the alleged debt to which the letter refers. A copy of this letter is attached as Exhibit A.   9.  Upon information and belief, the alleged debt referenced in Exhibit A was  allegedly incurred for personal medical services and ambulance transportation.  