11. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   12. Some time prior to March 18, 2019, an obligation was allegedly incurred to THE  29. Plaintiffs bring this claim on behalf of the following class, pursuant to Fed. R. Civ. P. 23(a)  and 23(b)(3).  The class consists of (a) all individuals with addresses in the State of  Massachusetts (b) to whom Defendant (c) sent an initial collection letter attempting to  collect a consumer debt owed to THE VERIDIAN (d) containing the following language  “Unless you, within thirty days after receipt of this notice, notify us that you dispute any  portion of this debt, the debt will be assumed to be valid.” (e) which letter was sent on or  after a date one year prior to the filing of this action and on or before a date 21 days after  the filing of this action.   30. The identities of all class members are readily ascertainable from the records of Defendant  and those companies and entities on whose behalf they attempt to collect debts.   31. Excluded from the Plaintiff Class are the Defendant and all officers, members, partners,  managers, directors, and employees of the Defendant and their respective immediate  families, and legal counsel for all parties to this action and all members of their immediate  families.   33. The Plaintiff’s claims are typical of the class members, as all are based upon the same facts  and legal theories.   34. 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 Plaintiff’s  attorneys have any interests, which might cause them not to vigorously pursue this action.   36. Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure is also  appropriate in that the questions of law and fact common to members of the Plaintiff Class  predominate over any questions affecting an individual member, and a class action is  superior to other available methods for the fair and efficient adjudication of the  controversy.   37. 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).  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, 1692e(2),  1692e(5) and 1692e(10).    40. Pursuant to Section 15 U.S.C. §1692e of the FDCPA, a debt collector may not use any  false, deceptive, or misleading representation or means in connection with the collection  of any debt.    41. The Defendant violated said provision by using false, deceptive and misleading  representations in connection with the collection of a debt in violation of 15 U.S.C.  §1692e(10).   42. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant’s conduct  violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs and  attorneys’ fees.   43. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs above  herein with the same force and effect as if the same were set forth at length herein.   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. § 1692g.   45. The Defendant violated said section by:  • Failing to provide an accurate validation notice in violation of §  1692g(a)(3).   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692g et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e et seq.  