13.  On or about August 31, 2016, Synchrony mailed a debt collection letter to  Plaintiff regarding an alleged debt owed to Synchrony. A copy of this letter is attached to this  complaint as Exhibit A.   15.  Exhibit A states:   16.  Exhibit A states that September 15, 2016 is the last day for payment and if  Plaintiff pays by this date, she "may continue with the contract as though [she was] not late."   17.  On or about September 8, 2016, Synchrony mailed another debt collection letter  to Plaintiff regarding the same alleged debt owed to Synchrony. A copy of this letter is attached  to this complaint as Exhibit B.   18.  Upon information and belief, Exhibit B is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.   19.  Exhibit B states:   20.  On or about September 29, 2016, Central Credit Services, LLC ("CCS") mailed a  debt collection letter to Plaintiff regarding the same alleged debt owed to Synchrony, referred to  in Exhibit A. A copy of this letter is attached to this complaint as Exhibit C.   21.  Exhibit C was the first letter that CCS sent to Plaintiff with respect to Plaintiff’s  alleged Synchrony debt.   23.  Exhibit C states:   24.  Exhibit C also states:   25.  Exhibit C, thus, represents that the debt had been accelerated and the full balance  is now due.    26.  Despite Exhibit A’s statement that September 15, 2016 was the last day for  payment to cure default and "continue with the contract as though you were not late," and despite  Synchrony’s and CCS’s representations that the debt had been placed with CCS for collection  (Exhibit C) and that the debt had been accelerated and the full balance was now due, on or  around September 27, 2016, Synchrony sent Plaintiff an account statement for the same account,  demanding a minimum payment of $344.00. A copy of this statement is attached to this  complaint as Exhibit D.   27.  Synchrony’s representation in Exhibit A that the last day for payment to cure  default is September 15, 2016 in order to continue with the contract as though Plaintiff was not  late is false and misleading, especially when the consumer is subsequently presented with  account statements requesting minimum payments lower than the total balance (Exhibit D).   28.  The unsophisticated consumer cannot determine whether the debt had been  accelerated or not, or how much debt is actually due. Exhibit C seeks the entire amount of the  debt, $2021.00, but Exhibit D seeks only $344.00.   30.  Upon information and belief, CCS and Synchrony work in a scripted process to  collect Synchrony debts such as Plaintiff’s.   31.  Upon information and belief, CCS is fully aware of the contents and  representations in Exhibit A,    32.  Upon information and belief, CCS is fully aware that Synchrony sends Exhibit A  to consumers approximately one month before CCS mails a letter in the form of Exhibit C.   33.  Upon information and belief, CCS is fully aware that Synchrony continues to  send statements to consumers seeking a “minimum payment” and not representing that the entire  balance is due.   34.  Plaintiff was confused by Exhibits A-D.   35.  The unsophisticated consumer would be confused by Exhibits A-D.   36.   Plaintiff had to spend time and money investigating Exhibits A-D.   37.  Plaintiff had to take time to obtain and meet with counsel, including traveling to  counsel’s office by car and its related expenses, including but not limited to the cost of gasoline  and mileage, to advise Plaintiff on the consequences of Exhibits A-D.   38.  The FDCPA presumes that violations cause injury to consumers. Congress  authorized an award of statutory damages for violations. 15 U.S.C. § 1692k(a).   40.  15 U.S.C. § 1692e generally prohibits “any false, deceptive, or misleading  representation or means in connection with the collection of any debt.”   41.  15 U.S.C. § 1692e(2)(a) specifically prohibits “The false representation of – the  character, amount, or legal status of any debt.”   42.  15 U.S.C. § 1692e(10) specifically prohibits the “use of any false representation  or deceptive means to collect or attempt to collect any debt.”   43.  15 U.S.C. § 1692g(a) requires:  (a) Notice of debt; contents   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—   (1) the amount of the debt;    44.  The FDCPA requires the debt collector to state the amount due on the date the  collection letter is sent, “without “obscur[ing] it by adding confusing other information (or  misinformation).” Miller v. McCalla, Raymer, Padrick, Cobb, Nichols, & Clark, L.L.C., 214  F.3d 872, 875-76 (7th Cir. 2000); Marshall-Mosby v. Corporate Receivables, Inc., 205 F.3d 323,  326 (7th Cir. 2000); Bartlett v. Heibl, 128 F.3d 497, 500 (7th Cir. 1997).    45.  Wis. Stat. § 427.104(1)(j) states that a debt collector may not: “Claim, or attempt  or threaten to enforce a right with knowledge or reason to know that the right does not exist.”   47.  Plaintiff incorporates by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   48.  This claim is brought against Defendant CCS.   49.  CCS represented to Plaintiff and class members that their Synchrony accounts had  been accelerated by seeking to collect the entire balance and not just the amount actually due.   50.  Prior to sending Exhibit C, which demands payment of the balance of the PayPal  credit account, CCS was aware that Synchrony would continue to send statements seeking a  “minimum payment” lower than the balance.   51.  At the time it sent Exhibit C to the class, CCS knew that Synchrony would  continue to send class members account statements seeking a “minimum payment” lower than  the account balance.   52.  CCS made false, misleading and confusing representations about the amount of  the debt.   53.  CCS’s conduct violates 15 U.S.C. §§ 1692e, 1692e(10), 1692g and 1692g(a).  54.  Plaintiff incorporates by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint. This claim is brought against both  defendants.   56.  Original creditors, including Synchrony, are debt collectors under the WCA. Wis.  Stat. § 427.103; Hartman, 191 F. Supp. 2d at 1048.   57.  In Exhibit C, CCS represented to Plaintiff and class members that their Synchrony  accounts had been accelerated so that the entire balance was due.   58.  In fact, when CCS sent Exhibit C, CCS and Synchrony both knew that Synchrony  would continue to send class members account statements seeking a minimum payment of less  than the entire balance.   59.  CCS’s and Synchrony’s conduct violates the Wisconsin Consumer Act, Wis. Stat.  §§ 427.104(1)(j) and 427.104(1)(L).  60.  Plaintiff incorporates by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint. This claim is brought against both  defendants.   61.  Exhibits A and C provide facially conflicting deadlines for payment.   62.  CCS’s and Synchrony’s conduct violates the Wisconsin Consumer Act, Wis. Stat.  §§ 427.104(1)(h) and 427.104(1)(L).  64.  The Class is so numerous that joinder is impracticable. Upon information and  belief, there are more than 50 members of the Class.   65.  There are questions of law and fact common to the members of the class, which  common questions predominate over any questions that affect only individual class members.   The predominant common question is whether Exhibits A, C and D violate the FDCPA and/or  the WCA.   66.  Plaintiff’s claims are typical of the claims of the Class members.  All are based on  the same factual and legal theories.   67.  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.   68.  A class action is superior to other alternative methods of adjudicating this dispute.    Individual cases are not economically feasible. 