1. An order certifying that Count I may be maintained as a class action pursuant to  Rule 23 of the Federal Rules of Civil Procedure and appointing Plaintiff and the  undersigned counsel to represent the class previously set forth and defined above.   14. Sometime prior to February 1, 2019, Plaintiff allegedly incurred a debt to Credit One Bank, N.A.  (“Credit One”) related to a personal credit card account with an account number ending in 5609  (the “Debt”).   15. The Debt arose 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,  namely fees emanating from a personal credit card account in Plaintiff’s name that was issued by  Credit One.     16. The Debt arose out of a credit card account which Plaintiff opened for his personal use.    17. Plaintiff’s credit card account that was issued by Credit One was neither opened nor used  by Plaintiff for business purposes.    18. Plaintiff’s personal credit card account Debt to Credit One is a “debt” as defined by 15  U.S.C. § 1692a(5).    19. Sometime after the incurrence of the Debt, but before the initiation of this action, Plaintiff was  alleged to have fallen behind on payments owed on the alleged Debt.   2. Adjudging that Defendant violated 15 U.S.C. §§ 1692e and 1692e(8);   20. The Debt went into default because of non-payment.    21. After the Debt went into default, the Debt was allegedly sold by Credit One to MCM.    23. MCM claims that they purchased the Debt and are now the entity to whom the Debt is  owed.    24. MCM contends that the Debt is in default.    25. The Debt was in default at the time the Debt was allegedly purchased by MCM.    26. Plaintiff disputes the Debt.    27. At all times relevant hereto, MCM acted in an attempt to collect the Debt.    28. On or about February 22, 2019, MCM began reporting the Debt to the three major credit  bureaus, Equifax, Experian, and TransUnion (the “Credit Bureaus”).    29. MCM reported the Debt to the Credit Bureaus as “In Collection” and with a “Past Due”  amount of $1,131.    3. An award of statutory damages for Plaintiff and the class members pursuant to 15  U.S.C. §1692k;    30. MCM reported the Debt to the Credit Bureaus as a part of their efforts to collect the Debt.    31. MCM’s reporting of the Debt to the Credit Bureaus is a “communication” as that term is  defined by 15 U.S.C. § 1692a(2).   32. On or about February 28, 2020, Plaintiff mailed two letters to MCM (the “Letters”).  (Annexed and attached hereto as Exhibit A is a copy of the Letters that Plaintiff mailed to  MCM, except the undersigned counsel has in accordance with Fed. R. Civ. P. 5.2  redacted the financial account numbers and Plaintiff’s street address to protect his  privacy)   33. The Letters concerned the same Debt and stated:   I am disputing the above referenced debt and refuse to pay it under any  circumstances.    35. The Letters were received by MCM at their respective addresses in the first or second  week of March of 2020.    36. The Letters were not returned to Plaintiff as undeliverable.    37. In March of 2020, MCM had actual written notice from Plaintiff in the form of the  Letters attached as Exhibit A that he disputed the Debt.    38. On May 22, 2020, Plaintiff obtained his credit report from TransUnion.   39. On the credit report from TransUnion the Plaintiff obtained on May 22, 2020, MCM was  reporting the Debt. (Annexed and attached hereto as Exhibit B is a copy of the relevant  portion of the credit report from TransUnion the Plaintiff obtained on May 22, 2020  showing the Debt being reported by MCM)   4. Attorneys’ fees, litigation expenses and costs of suit pursuant to 15 U.S.C.  §1692k; and    40. On the credit report from TransUnion the Plaintiff obtained on May 22, 2020, MCM was  not reporting that the Debt was disputed.    41. Nowhere does the credit report attached as Exhibit B indicate that the Debt is disputed by  the Plaintiff.    42. The credit report from TransUnion the Plaintiff obtained on May 22, 2020 states that  MCM last updated their reporting on the Debt on May 12, 2020.    43. Approximately two months prior to May 12, 2020, MCM had actual knowledge in the  form of the Letters attached as Exhibit A that Plaintiff disputed the Debt.    45. Plaintiff incorporates by reference all of the above paragraphs as though fully stated  herein.   46. The conduct of the Defendant in this case violates 15 U.S.C. §§ 1692 and 1692e(8).    47. 15 U.S.C. §1692e provides:   A debt collector may not use any false, deceptive, or misleading representation or means in  connection with the collection of any debt. Without limiting the general application of the  foregoing, the following conduct is a violation of this section:  (8) Communicating or threatening to communicate to any person credit information  which is known or which should be known to be false, including the failure to  communicate that a disputed debt is disputed.   48. MCM violated 15 U.S.C. § 1692e(8) because they failed to communicate to the Credit  Bureaus that the Debt was disputed despite having actual written notice in the form of the  Letters from the Plaintiff that the Debt was disputed.    49. According to the credit report attached as Exhibit B, on May 12, 2020, MCM reported  Plaintiff’s Debt to the credit bureaus without notifying the Credit Bureaus that the Debt  was disputed. This violated 15 U.S.C. § 1692e(8) because MCM had actual knowledge in  the form of the Letters they received from the Plaintiff in March of 2020 that the Debt  was disputed. Despite this actual knowledge that the Debt was disputed, MCM did not  report the Debt as disputed to the Credit Bureaus in violation of § 1692e(8).    50. The violations of the FDCPA described herein constitute per se violations.   52. Plaintiff has alleged a concrete harm because the FDCPA creates a substantive right to be  free from abusive and misleading debt communications and Defendant’s violations of the  FDCPA resulted in concrete harm to Plaintiff.   53. Defendant is liable to the Plaintiff and the proposed class pursuant to 15 U.S.C. § 1692k because  of the above FDCPA violations.   54. Plaintiff incorporates by reference all of the above paragraphs as though fully stated  herein.   55. This action is brought as a class action. Plaintiff brings this action on behalf of himself and on  behalf of all other persons similarly situated pursuant to Rule 23 of the Federal Rules of Civil  Procedure.    56. The Class is initially defined as (a) all consumers (b) with a New Jersey address (c) who disputed  a debt that MCM was reporting to any of the Credit Bureaus (d) after receiving notification of  the dispute MCM continued to report the debt to the Credit Bureaus without notifying the Credit  Bureaus that the disputed debt was disputed, (e) on or after a date one year prior to the filing of  this action.     57. The class definition above may be subsequently modified or refined in an amended  complaint or in any motion for class certification.    VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  (15 U.S.C. §1692e)  