10.  Upon information and belief,   was an Amazon.com-branded credit card  account, and the alleged debt was incurred for personal, family or household purposes, including  purchases of household goods on Amazon’s website.  Exhibit A  11.   is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.   Exhibit A  12.   was the first letter EGS sent to Plaintiff regarding this alleged debt.  Exhibit A  13.  EGS’s letter as a whole is confusing and misleading to the unsophisticated  consumer.   includes the FDCPA debt validation notice. 15 U.S.C. § 1692g(a).   14.  Exhibit A  states:   15.  Exhibit A  also states:   17.  The bottom of Exhibit A  is a “payment coupon.” It states:   18.  Exhibit A  is confusing to the unsophisticated consumer. It is unclear whether EGS  is collecting the entire $2,032.00 balance or just the $234.00 that was represented to be the  “Amount Now Due.”    19.  EGS compounds the confusion by stating that Synchrony “has placed the above  account with our office for collection,” (emphasis added) and including both amounts on the  payment coupon at the bottom of Exhibit A  20.  It is not unusual for banks to hire a debt collector to collect only the “past due”  amount, i.e. missed payments and fees, of a credit card balance rather than the whole balance.  The Seventh Circuit held in Barnes v. Advanced Call Ctr. Techs., LLC, 493 F.3d 838, 840 (7th  Cir. 2007), that “ .   21.  The different amounts on  only the past due amount, the amount owed [to the debt collector], can be the  ‘amount of the debt’ under § 809(a)(1).” Whichever number EGS is truly collecting, it need only  state that amount in the letter.  Exhibit A render Exhibit A  22.  The alleged debt or debts here is an unsecured credit card account.    confusing to the  unsophisticated consumer, who would not be able to determine, or would be confused as to,  which amount EGS was actually attempting to collect.   24.  15 U.S.C. § 1692e generally prohibits “  25.  any false, deceptive, or misleading  representation or means in connection with the collection of any debt.”  15 U.S.C. § 1692e(2)(a) specifically prohibits the “false representation of   26.  the  character, amount, or legal status” of an alleged debt.  15 U.S.C. § 1692e(10) specifically prohibits the “  27.  use of any false representation  or deceptive means to collect or attempt to collect any debt.”  15 U.S.C. § 1692f generally prohibits  “unfair or unconscionable means to collect  or attempt to collect any debt.”   28.  Plaintiff was confused by Exhibit A  29.  The unsophisticated consumer would be confused by  .  Exhibit A  30.  Plaintiff had to spend time and money investigating  .   Exhibit A, and the  consequences of any potential responses to Exhibit A  31.  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  .  Exhibit A  34.  Plaintiff incorporates by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   35.  EGS represented the amount of the debt that EGS was attempting to collect in a  confusing manner by stating multiple amounts that EGS was attempting to collect. Exhibit A.    36.  The unsophisticated consumer would be confused as to whether EGS was  attempting to collect only the “Amount Now Due” or the total balance.   37.  EGS’s conduct violates 15 U.S.C. §§ 1692e, 1692e(2)(a), 1692e(10), 1692(f) and  1692g(a)(1).  38.  Plaintiff brings this action on behalf of a Class consisting of (a) all natural persons  in the State of Wisconsin, (b) who were sent an initial collection letter in the form represented by  Exhibit A to the complaint in this action, (c) seeking to collect a debt, incurred for personal,  family or household purposes (d) between July 31, 2016 and July 31, 2017, inclusive, (e) that  was not returned by the postal service.   39.  The Class is so numerous that joinder is impracticable.  Upon information and  belief, there are more than 50 members of the Class.   40.  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 Exhibit A violates the FDCPA.   42.  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.   43.  A class action is superior to other alternative methods of adjudicating this dispute.    Individual cases are not economically feasible.   44.  Plaintiff hereby demands a trial by jury.  9.  The alleged debt referenced in  .  Exhibit A  Exhibit A 