10.  Defendant uses the mails, telephone, the internet and other instruments of  interstate commerce in engaging in the business of collecting past-due or defaulted debts or  alleged debts of natural persons which arise from transactions which are primarily for personal,  family, or household purposes.   12.  Defendant has asserted that Plaintiff incurred or owed a certain financial  obligation arising from an account originating from Honda Financial Services (“Debt” or  “Account”).   13.  The Debt arose from one or more transactions which were primarily for Plaintiff’s  personal, family, or household purposes.   14.  The debts alleged to be owed by Plaintiff and those similarly situated were  incurred for personal, family or household purposes.   15.  Defendant contends that the Account is past-due and in default.   16.  At some point after Plaintiff’s alleged default, the original creditor of the Account  determined that the debt was uncollectable.   17.  Sometime after default, the creditor of the Account either directly or through  intermediate transactions assigned, placed, transferred or sold the Debt to Defendant for  collection.   18.  The Account was past-due and in default when it was placed with or assigned to  Defendant for collection.   19.  At all times relevant hereto, Defendant acted in an attempt to collect the Debt.  B. False Threat of Interest and Other Charges   20.  In an attempt to collect the Debt, Defendant mailed a collection letter to Plaintiff  on July 10, 2015 (“7/10/15 Letter”).   21.  A true copy of the 7/10/15 Letter, but with redactions, is attached as Exhibit A.   23.  The 7/10/15 Letter states, “The balance in the amount of $17051.59 is due in full  at this time.”   24.  The 7/10/15 Letter further states: “Because of interest, late charges, and other  charges that may vary from day to day your payment may be greater.”   25.  On information and belief and contrary to the statement contained in the 7/10/15  Letter, at no time after July 10, 2015 did the original creditor of the Account add “interest” to the  Account.   26.  On information and belief and contrary to the statement contained in the 7/10/15  Letter, at no time after July 10, 2015 did the original creditor of the Account add “late” charges  to the Account.   27.  On information and belief and contrary to the statement contained in the 7/10/15  letter, at no time after July 10, 2015 did the original creditor of the Account add “other changes”  to the Account.   28.  On information and belief, contrary to statements contained in the 7/10/15 Letter,  at no time does Defendant add “interest” to consumer debts, which are similar to the Account,  and which it seeks to collect.   29.  On information and belief, contrary to statements contained in the 7/10/15 Letter,  at no time does Defendant add “late charges” to consumer debts, which are similar to the  Account, and which it seeks to collect.   31.  On information and belief, Defendant is not legally or contractually permitted to  add “interest” to the Account.   32.  On information and belief, Defendant is not legally or contractually permitted to  add “late charges” to the Account.     33.  On information and belief, Defendant is not legally or contractually permitted to  add “other charges” to the Account.   34.  On information and belief, Honda Financial Services ceased sending periodic  statements and stopped charging additional interest and fees prior to Defendant’s sending of the  7/10/15 Letter.   35.  In fact, the balance for the Account remained the same at $17,051.59. See  Defendant’s collection letter dated February 7, 2016 attached as Exhibit B.   36.  Defendant’s statement that “[b]ecause of interest, late charges, and other charges  that may vary from day to day your payment may be greater” is false, deceptive, and misleading  to the least sophisticated consumer because Defendant falsely suggests that the amount of the debt  will increase from day to day because of interest, late charges, and other charges when, in fact, the  original creditor has stopped charging interest and fees.   37.  Such a false statement makes Plaintiff and the least sophisticated consumer  uncertain as to the amount allegedly owed to Honda Financial Services, and uncertain as to how  much additional interest, late charges, and other charges would continue to accrue.   41.  Plaintiff brings this action individually and as a class action on behalf of all others  similarly situated pursuant to Rule 23 of the Federal Rules of Civil Procedure.   42.  Subject to discovery and further investigation which may cause Plaintiff to modify,  narrow or expand the following class definition at the time Plaintiff moves for class certification,  Plaintiff seeks certification of a Class initially defined as follows:  All natural persons residing in the State of New Jersey to whom,  beginning July 9, 2015 through and including the final resolution  of this case, Defendant sent one or more letter(s) in attempts to  collect a consumer debt, which letter contained the same or  materially similar language: “Because of interest, late charges, and  other charges that may vary from day to day your payment may be  greater.”   43.  Plaintiff seeks to recover statutory damages, attorney’s fees and costs on behalf of  all class members under the Fair Debt Collection Practices Act.   44.  The Class for whose benefit this action is brought is so numerous that joinder of  all members is impracticable.   46.  A class action is superior to other available methods for the fair and efficient  adjudication of this controversy since joinder of all members is impracticable. The FDCPA  statutory scheme provides for statutory damages payable to each class member. A class action  will cause an orderly and expeditious administration of the claims of the Class and will foster  economies of time, effort and expense.   47.  Plaintiff’s claims are typical of the claims of the members of the Class.   48.  The questions of law and/or fact common to the members of the Class  predominate over any questions affecting only individual members.   49.  Plaintiff does not have interests antagonistic to those of the Class.   50.  The Class, of which Plaintiff is a member, is readily identifiable.   51.  Plaintiff will fairly and adequately protect the interests of the Class, and has  retained competent counsel experienced in the prosecution of consumer litigation.  Proposed  Class Counsel have investigated and identified potential claims in the action; have a great deal of  experience in handling class actions, consumer and other complex litigation, and claims of the  type asserted in this action.   53.  Plaintiff does not anticipate any difficulty in the management of this litigation.  54.  Plaintiff, on behalf of herself and others similarly situated, reasserts and  incorporates herein the allegations contained in the preceding and following paragraphs.   55.  Plaintiff and those similarly situated are “consumers” as defined by 15 U.S.C. §  1692a(3) because they are natural persons allegedly obligated to pay a debt, in which the money,  property, insurance, or services, which was the subject of the transaction, was primarily for  personal, family and/or household purposes.   56.  The debts alleged to be owed by the Plaintiff and those similarly situated are  consumer “debts” as defined by 15 U.S.C. § 1692a(5).   57.  Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6).   58.  The 7/10/15 Letter, copy of which appears in Exhibit A, is a “communication” as  defined by 15 U.S.C. § 1692a(2).   59.  The letters, which are the same or similar in form to the 7/10/15 Letter, sent by  Defendant to other New Jersey consumers are “communications” pursuant to 15 U.S.C. §  1692a(2).   61.  Defendant’s use of the written communications as described above, sent to  Plaintiff and those similarly situated, violated the FDCPA in one or more of the following ways:  a.  Defendant  made  false,  deceptive  or  misleading  representations or means in connection with the collection of a  debt, in violation of 15 U.S.C. § 1692e;  b.  Defendant made false representations of the character,  amount, or legal status of a debt, in violation of 15 U.S.C. §  1692e(2)(A);  c.  Defendant threatened to take any action that cannot legally  be taken or that is not intended to be taken, in violation of 15  U.S.C. § 1692e(5);  d.  Defendant used false representations or deceptive means to  collect or attempt to collection a debt, in violation of 15 U.S.C. §  1692e(10).  e.  Defendant used unfair or unconscionable means to collect  or attempt to collect a debt, in violation of 15 U.S.C. § 1692f;   f.  Defendant attempted to collect any amount (including any  interest, fee, charge, or expense incidental to the principal  obligation) not expressly authorized by the agreement creating the  debt or permitted by law, in violation of 15 U.S.C. § 1692f(1); and  g.  Defendant failed to properly disclose the amount of the  debt, in violation of 15 U.S.C. § 1692g(a)(1).   62.  The violations of the FDCPA described herein constitute per se violations.   63.  Based on any one or more of those violations, Defendant is liable to Plaintiff and  those similarly situated for damages, attorney’s fees and costs under 15 U.S.C. § 1692k.  7.  Defendant is not in the business of extending credit, selling goods or services to  consumers.   8.  Defendant regularly collects or attempts to collect past-due or defaulted debts  allegedly owed to others which were incurred primarily for personal, family or household  purposes.   9.  Defendant is in the business of collecting past-due or defaulted debts or alleged  debts of natural persons.   A. Background  