1.”)   21.  Defendant alleges Plaintiff owes a debt (“the alleged Debt”).     22.  The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of  a transaction in which the money, property, insurance, or services which are the subject of the  transaction are primarily for personal, family, or household purposes.   23.  The alleged Debt does not arise from any business enterprise of Plaintiff.   25.  At an exact time known only to Defendant, the alleged Debt was assigned or  otherwise transferred to Defendant for collection.    26.  At the time the alleged Debt was assigned or otherwise transferred to Defendant  for collection, the alleged Debt was in default.   27.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff by letter  (“the Letter”) dated October 8, 2018. (A true and accurate copy is annexed hereto as “Exhibit   28.  The Letter conveyed information regarding the alleged Debt.   29.  The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).    30.  The Letter was the initial written communication Plaintiff received from  Defendant concerning the alleged Debt.   31.  The Letter was received and read by Plaintiff.   32.  15 U.S.C. § 1692g protects Plaintiff's concrete interests. Plaintiff has the interest  and right to receive a clear, accurate and unambiguous validation notice, which allows a  consumer to confirm that he or she owes the debt sought to be collected by the debt collector. As  set forth herein, Defendant deprived Plaintiff of this right.   33.  15 U.S.C. § 1692e protects Plaintiff's concrete interests. Plaintiff has the interest  and right to be free from deceptive and/or misleading communications from Defendant. As set  forth herein, Defendant deprived Plaintiff of this right.   34.  The deprivation of Plaintiff's rights will be redressed by a favorable decision  herein.  35.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     37.  15 U.S.C. § 1692g(a)(3) provides that the written notice must contain a statement  that unless the consumer, within thirty days after receipt of the notice, disputes the validity of the  debt, or any portion thereof, the debt will be assumed to be valid by the debt collector.   38.  15 U.S.C. § 1692g(a)(4) provides that the written notice must contain a statement  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 will obtain verification of the debt or a  copy of a judgment against the consumer and a copy of such verification or judgment will be  mailed to the consumer by the debt collector.   39.  In order to be entitled to obtain verification of the debt or a copy of a judgment  against the consumer, the consumer must dispute the debt in writing.     40.  15 U.S.C. § 1692g(a)(5) provides that the written notice must contain 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.   41.  In order to be entitled to obtain the name and address of the original creditor, if  different from the current creditor, the consumer must request such in writing.     42.  A debt collector has the obligation not just to convey the 15 U.S.C. § 1692g  required disclosures, but also to convey such clearly.    43.  Even if a debt collector conveys the required information accurately, the debt  collector nonetheless violates the FDCPA if that information is overshadowed or contradicted by  other language in the communication.     44.  Even if a debt collector conveys the required information accurately, the debt  collector nonetheless violates the FDCPA if that information is overshadowed by other collection  activities during the 30-day validation period following the communication.   45.  15 U.S.C. § 1692g(b) provides that collection activities and communication  during the 30-day period may not overshadow or be inconsistent with the disclosure of the  consumer's right to dispute the debt or request the name and address of the original creditor.   46.  A collection activity or communication overshadows or contradicts the validation  notice if it would make the least sophisticated consumer uncertain or confused as to her rights.   48.  The first address, located in the coupon, is: Dept. 96307 PO Box 1259 Oaks, PA  19456.   49.  The second address, located in the coupon, is: 4839 N Elston Ave Chicago IL  60630.   50.  The third address, located in the coupon, is: PO Box 301122 Chicago IL 60630.   51.  In order to be entitled to obtain verification of the debt or a copy of a judgment  against the consumer pursuant to 15 U.S.C. § 1692g(a)(4), the consumer must dispute the debt in  writing.     52.  The Letter fails to instruct the consumer to which of the multiple addresses  provided written disputes must be sent.   53.  As a result of the foregoing, the least sophisticated consumer would likely be  confused as to which of the multiple addresses she should send her written dispute.     54.  As a result of the foregoing, the least sophisticated consumer would likely be  uncertain as to which of the multiple addresses she should send her written dispute.     55.  Without clear direction as to where to mail her written dispute, the least  sophisticated consumer would likely not dispute the debt at all.   56.  Without clear direction as to where to mail her written dispute, the least  sophisticated consumer would likely not dispute the debt at all because she would be frightened  of calling the collection agency where highly trained and aggressive debt collectors answer calls.   57.  As a result of the foregoing, the Letter would likely discourage the least  sophisticated consumer from exercising her right to dispute the debt.     58.  In order to be entitled to obtain the name and address of the original creditor  pursuant to 15 U.S.C. § 1692g(a)(5), the consumer must request such in writing.     59.  The Letter fails to instruct the consumer to which of the multiple addresses  provided requests for the name of the original creditor must be sent.   60.  As a result of the foregoing, the least sophisticated consumer would likely be  confused as to which of the multiple addresses she should send her request for the name of the  original creditor.     62.  Without clear direction as to where to mail her request for the name of the  original creditor, the least sophisticated consumer would likely not request this information at all.   63.  Without clear direction as to where to mail her request for the name of the  original creditor, the least sophisticated consumer would likely not request this information at all  because she would be frightened of calling the collection agency where highly trained and  aggressive debt collectors answer calls.   64.  As a result of the foregoing, the Letter would likely discourage the least  sophisticated consumer from exercising her right to request for the name of the original creditor.   65.  As a result of the foregoing, the multiple addresses would likely make the least  sophisticated consumer confused as to her rights.   66.  As a result of the foregoing, the multiple addresses would likely make the least  sophisticated consumer uncertain as to her rights.   67.  Defendant violated 15 U.S.C. § 1692g(b) as the multiple addresses overshadow  the disclosure of the consumer's right to dispute the debt provided by 15 U.S.C. § 1692g(a)(3).   68.  Defendant violated 15 U.S.C. § 1692g(b) as the multiple addresses overshadow  the disclosure of the consumer's right to receive verification of the debt or a copy of a judgment  against the consumer provided by 15 U.S.C. § 1692g(a)(4).   69.  Defendant violated 15 U.S.C. § 1692g(b) as the multiple addresses overshadow  the disclosure of the consumer's right to request the name and address of the original creditor  provided by 15 U.S.C. § 1692g(a)(5).   70.  Defendant violated 15 U.S.C. § 1692g(b) as the multiple addresses are  inconsistent with the disclosure of the consumer's right to dispute the alleged Debt provided by  15 U.S.C. § 1692g(a)(3).   71.  Defendant violated 15 U.S.C. § 1692g(b) as the multiple addresses are  inconsistent with the disclosure of the consumer's right to receive verification of the debt or a  copy of a judgment against the consumer provided by 15 U.S.C. § 1692g(a)(4).   72.  Defendant violated 15 U.S.C. § 1692g(b) as the multiple addresses are  inconsistent with the disclosure of the consumer's right to request the name and address of the  original creditor provided by 15 U.S.C. § 1692g(a)(5).   74.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     75.  A debt collection practice can be a “false, deceptive, or misleading” practice in  violation of 15 U.S.C. § 1692e even if it does not fall within any of the subsections of 15 U.S.C.  § 1692e.  Clomon, 988 F.2d at 1318.    76.  A collection letter violates 15 U.S.C. § 1692e if, in the eyes of the least  sophisticated consumer, it is open to more than one reasonable interpretation, at least one of  which is inaccurate. Clomon, 988 F.2d at 1319.   77.  A  collection  letter  also  violates  15  91.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.   92.  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.   93.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     94.  A debt collection practice can be a “false, deceptive, or misleading” practice in  violation of 15 U.S.C. § 1692e even if it does not fall within any of the subsections of 15 U.S.C. §  1692e.  Clomon, 988 F.2d at 1318.    95.  A collection letter violates 15 U.S.C. § 1692e if, in the eyes of the least  sophisticated consumer, it is open to more than one reasonable interpretation, at least one of  which is inaccurate. Clomon, 988 F.2d at 1319.   96.  A  collection  letter  also  violates  15  Violation of 15 U.S.C. §§ 1692g(b), 1692e and 1692e(10)   Violations of 15 U.S.C. §§ 1692e and 1692e(10)  