12.  Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   14.  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.   15.  Excluded from the Plaintiff Classes 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.    16.  There are questions of law and fact common to the Plaintiff Classes, 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, violates 15 U.S.C. §§ l692e and 1692g.   17.  The Plaintiffs' claims are typical of the class members, as all are based upon the  same facts and legal theories. The Plaintiffs will fairly and adequately protect the interests of  the Plaintiff Classes defined in this complaint. The Plaintiffs have retained counsel with  experience in handling consumer lawsuits, complex legal issues, and class actions, and neither  the Plaintiffs nor their attorneys have any interests, which might cause them not to vigorously  pursue this action.   19.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Classes predominate over any questions affecting an individual member, and a class action is  superior to other available methods for the fair and efficient adjudication of the controversy.   20.  Depending on the outcome of further investigation and discovery, Plaintiffs 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).  21.  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.   22.  Some time prior to January 10, 2018, an obligation was allegedly incurred to Chase  Bank U.S.A., N.A. (“Chase”).   23.  The Chase 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.   24.  The alleged Chase Bank U.S.A., N.A. obligation is a "debt" as defined by 15  U.S.C. § 1692a(5).   25.  Chase is a "creditor" as defined by 15 U.S.C. §1692a(4).   27.  Defendant 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 Service, telephone and internet.  Violation I – January 10, 2018 Collection Letter   28.  On or about January 10, 2018, Defendant sent the Plaintiff a collection letter (the  “Letter”) regarding the alleged debt owed to Chase Bank U.S.A., N.A., with an outstanding  balance due in the amount of $2,231.28. See Exhibit A.   29.  Defendant’s January 10, 2018 Collection Letter contained language that implies  that the consumer may enhance its likelihood of future approval for credit products by paying  the alleged debt in full, rather than accept a reduced settlement amount.   30.  Specifically, the third paragraph of Defendant’s letter contained an offer to settle  the $2,231.28 balance for a reduced amount of $669.39.    31.  However, the fourth paragraph continues : “If we settle this debt with you for less  that the full outstanding balance, Chase may offer you less favorable terms in the future for  some Chase products or services or may deny your application.”   32.  This language implies that if the Plaintiff settles the stated balance for a reduced  amount, as opposed to paying the stated balance in full, Plaintiff may reduce her likelihood of  receiving future credit products from Chase Bank or reduce her overall creditworthiness.   34.  Further this language is deceptive and overshadowing as it does not truly afford the  consumer of its proper rights and ability to dispute the debt, as it encourages only payment in  full of the stated amount of the debt rather than disputing and only paying part of it.    35.  As a result of Defendant's deceptive, misleading and unfair debt collection  practices, Plaintiff has been damaged.  36.  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.   37.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   38.  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.   39.  Defendant violated said section by:   a. Making a false and misleading representation in violation of §1692e(10).  b. Specifically, by falsely implying that payment in-full (rather than settlement) of  the claimed debt would have enhanced her likelihood of receiving future credit  products or enhanced her overall creditworthiness.   41.  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.   42.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692g.   43.   Pursuant to 15 USC §1692g, a debt collector:   45.  The FDCPA further provides that if the consumer notifies the debt collector in  writing within the thirty day period . . . that the debt, or any portion thereof, is disputed . . . the  debt collector shall cease collection . . . until the debt collector obtains verification of the  debt . . . and a copy of such verification is mailed to the consumer by the debt collector. 15  U.S.C. § 1692g(b).   46.  Although a collection letter may track the statutory language, ''the collector  nonetheless violates the Act if it conveys that information in a confusing or contradictory  fashion so as to cloud the required message with uncertainty.'' Russell, 74 F.3d at 35 (''It is not  enough for a debt collection agency simply to include the proper debt validation notice in a  mailing to a consumer-- Congress intended that such notice be clearly conveyed.''). Put  differently, a notice containing ''language that 'overshadows or contradicts' other language  informing a consumer of her rights ... violates the Act.'' Russell, 74 F.3d at 34.   47.  Although this letter contained the required language it also contained language that  implies that the consumer may enhance its likelihood of future approval for credit products by  paying the alleged debt in full, rather than accept a reduced settlement amount.   48.  The Defendant violated §1692g as the letter contains language that overshadows  the Plaintiff’s validation rights and notice of ability to dispute the debt.   50.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692g et seq. of the FDCPA, actual damages, statutory damages,  costs and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C.  §1692g et seq.  