1. The amount of the debt; …   11.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   12.  The Class consists of:   a. all individuals with addresses in the State of North Dakota;  b. to whom Defendant Alltran sent a collection letter;  c. attempting to collect a consumer debt;  d. that states an amount owed for “Fees & Other Non-Collection Charges”;  e. without explaining what these charges consist of;  f. which letter was sent on or after a date one year prior to the filing of this action  and on or before a date twenty-one days after the filing of this action.   13.  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.  There are questions of law and fact common to the Plaintiff Class, which common  issues predominate over any issues involving only individual class members. The principal issue is  whether the Defendant’s written communication to consumers, in the forms attached as Exhibit A,  violate 15 U.S.C. §§ 1692e, 1692f, and 1692g.   16.  The Plaintiff’s claims are typical of the class members, as all are based upon the  same facts and legal theories. The Plaintiff will fairly and adequately protect the interests of the  Plaintiff Class defined in this complaint. The Plaintiff has retained counsel with experience in  handling consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiff nor  his attorneys have any interests, which might cause them not to vigorously pursue this action.   19.  Depending on the outcome of further investigation and discovery, Plaintiff 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).  20.  Plaintiff repeats the above allegations as if set forth here.   21.  Some time prior to February 18, 2020, Plaintiff allegedly incurred an obligation to  the University of Northern Iowa.   22.  The obligation arose out of a transaction in which money, property, insurance or  services were incurred for personal purposes, specifically personal educational services from the  University of Northern Iowa.   23.  The alleged University of Northern Iowa obligation is a "debt" as defined by 15  U.S.C. § 1692a (5).   24.  University of Northern Iowa is a "creditor" as defined by 15 U.S.C. § 1692a (4).   25.  University of Northern Iowa contracted with the Defendant to collect the alleged  debt.   26.  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 Services, telephone and internet.  Violation - February 18, 2020 Collection Letter   28.  The collection letter states:   Principal: $999.00  Interest: $218.82  Collection Cost: $413.04  Fees and Other Non-Collection Charges: $21.24  Total Balance: $1,652.10   29.  The letter does not explain the term “Fees and Other Non-Collection Charges” and  Plaintiff has no way of determining what the “Fees and Other Non-Collection Charges” may be.   30.  Plaintiff has no basis to determine which “Fees and Other Non-Collection Charges”  could impact the total balance in addition to interest and collection costs.   31.  Furthermore, upon information and belief, the amount of the “Collection Cost” is  not authorized by agreement or otherwise permitted.    32.  Defendant unfairly attempted to collect an amount that is not provided in the  contract or by law.     33.  The letter further states, “Because of interest, late charges, and other charges that  may vary from day to day, the amount due on the day you pay may be greater.”   34.  In fact, however, there are no other charges that vary from day to day.   35.  If Defendant is aware of “other charges” that would increase the balance,  Defendant should clarify and explain them in the letter.   36.  Plaintiff is unable to evaluate how much is owed, and what charges may actually be  included in the overall balance at the time of payment.   38.  Plaintiff repeats the above allegations as if set forth here.   39.  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.   40.  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.   41.  Defendant violated said section by:   a. Making a false and misleading representation in violation of but not limited to  §1692e (10);  b. Falsely representing the amount of the debt in violation of § 1692e (2)(A);  c. Falsely threatening to increase the balance of the debt when such action could  not legally be taken or was not intended to be taken.   42.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e, et seq. of the FDCPA and is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  43.  Plaintiff repeats the above allegations as if set forth here.   44.  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. § 1692f.   46.  Defendant violated this section by   a. Attempting to collect amounts not authorized by contract or by law in violation  of § 1692f (1).   47.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692f, et seq. of the FDCPA and is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  48.  Plaintiff repeats the above allegations as if set forth here.   49.  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.   50.  Pursuant to 15 USC §1692g:  Within five days after the initial communication with a consumer in  connection with the collection of any debt, a debt collector shall, unless the  following information is contained in the initial communication or the  consumer has paid the debt, send the consumer a written notice containing –   51.  Defendant violated 15 U.S.C. §1692g by failing to properly state the amount owed.    VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692f et seq.   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.  