11.  Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   12.  The Class consists of:   a. all individuals with addresses in the State of New York;  b. to whom Defendant SBS sent a collection letter attempting to collect a  consumer debt;   c. that deceptively stated that both the original creditor and the debt collector  would report to the credit bureaus;   d. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (21) days after the filing of this action.  4   13.  The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf it attempts to collect debts and/or  has purchased debts.   14.  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.    15.  There are questions of law and fact common to the Plaintiff Class, which common  issues predominate over any issues involving only individual class members. The principal  issue is whether the Defendant’s written communications to consumers, in the forms attached  as Exhibits A, violate 15 U.S.C. §§ 1692e, 1692f.   16.  The Plaintiff’s claims are typical of the class members, as all are based upon the  same facts and legal theories. 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 his attorneys have any interests, which might cause them not to vigorously pursue this  action.   17.  This action has been brought, and may properly be maintained, as a class action  pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure because there is  a well-defined community interest in the litigation:  a. Numerosity: The Plaintiff is informed and believes, and on that basis alleges,  that the Plaintiff Class defined above is so numerous that joinder of all members  would be impractical.  5  b. Common Questions Predominate: Common questions of law and fact exist  as to all members of the Plaintiff Class and those questions predominance over  any questions or issues involving only individual class members. The principal  issue is whether the Defendant’s written communications to consumers, in the  forms attached as Exhibit A violate 15 U.S.C. § 1692e, 1692f.  c. Typicality: The Plaintiff’s claims are typical of the claims of the members of  the Plaintiff Class. The Plaintiff and all members of the Plaintiff Class have  claims arising out of the Defendants' common uniform course of conduct  complained of herein.  d. Adequacy: The Plaintiff will fairly and adequately protect the interests of the  Plaintiff Class insofar as Plaintiff has no interests that are adverse to the absent  members of the Plaintiff Class. The Plaintiff is committed to vigorously  litigating this matter. Plaintiff has also retained counsel experienced in handling  consumer lawsuits, complex legal issues, and class actions. Neither the Plaintiff  nor his counsel have any interests which might cause them not to vigorously  pursue the instant class action lawsuit.  e. Superiority: A class action is superior to the other available means for the fair  and efficient adjudication of this controversy because individual joinder of all  members would be impracticable. Class action treatment will permit a large  number of similarly situated persons to prosecute their common claims in a  single forum efficiently and without unnecessary duplication of effort and  expense that individual actions would engender.  6   18.  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 in that a class action  is superior to other available methods for the fair and efficient adjudication of the controversy.   19.  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).  20.  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.   21.  Some time prior to December 2, 2020, an obligation was allegedly incurred to  National Grid fka Keyspan NY.   22.  The National Grid fka Keyspan NY obligation arose out of an alleged debt for  transactions primarily for personal, family or household purposes, specifically utility  services.   23.  The alleged National Grid fka Keyspan NY obligation is a "debt" as defined by 15  U.S.C.§ 1692a(5).   24.  National Grid fka Keyspan NY is a "creditor" as defined by 15 U.S.C. § 1692a(4).   25.  Defendant SBS contracted with National Grid fka Keyspan NY to collect the  alleged debt.  7   26.  Defendant collects and attempts to collect debts incurred or alleged to have been  incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and internet.  Violation December 2, 2020 Collection Letter   27.  On or about December 2, 2020, Defendant sent the Plaintiff a collection letter (the  “Letter”) regarding the alleged debt owed to National Grid fka Keyspan NY. A true and correct  copy of the Letter is attached hereto as Exhibit A.   28.  The Letter states:  Notification of Intent to Process Negative Credit Report  We have not received your check in payment of this debt, and it is our obligation to inform  you that a negative credit report, in your creditors name, will be made regarding your lack  of cooperation with this matter.  This report will be processed in approximately thirty days,  unless full payment is received within twenty days from the date of this notification.   Kindly give this matter the immediate consideration that it deserves.   29.  The letter is unclear and deceptive if Defendant SBS will be doing the negative  credit reporting or if the original creditor will be doing the negative credit reporting or if both  the Defendant and the original creditor would be doing the negative reporting.   30.  The letter implies that Defendant SBS will be doing the reporting because   Defendant is informing the Plaintiff of the details of the reporting, yet the letter also states  that a negative credit report will be made in “your creditor’s name” implying that the original  creditor would also be reporting the negative credit information.   31.  It is deceptive to state that two companies will report to the credit reporting  agencies on the same debt.  8   32.  Moreover, the letter intimidates and threatens the consumer by implying that his  account information will be reported twice to the national credit reporting agencies.   33.  Plaintiff incurred an informational injury as Defendant falsely asserted that the  same debt would be reported twice to the national credit reporting agencies twice on the same  debt.   34.  In addition, the letter states that the negative credit reporting will be made  “regarding your lack of cooperation with this matter,” implying that somehow the credit  reporting will indicate “lack of cooperation.”   35.  The negative credit reporting would not include details such as “lack of  cooperation,” because it would only include basic indications regarding payment or lack  thereof (or late payments) and to include such language in the collection letter is false and  deceptive to the Plaintiff.    36.  As a result of Defendant's deceptive, misleading and unfair debt collection   practices, Plaintiff has been damaged.  44.  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.   45.  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. § 1692f.   46.  Pursuant to 15 U.S.C. §1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.   47.  Defendant violated this section by threatening to use language in a negative credit  reporting that would not be used.   48.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant’s  conduct violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692f  et seq.  