10.  In or about September, 2014, DEFENDANT mailed PLAINTIFF a collection  letter, attached hereto as Exhibit 1, in an attempt to collect a consumer debt from PLAINTIFF  allegedly owed to another.     11.  The letter states in pertinent part:  Unless you notify this office within (30) thirty days after receiving this notice that  you dispute the validity of this debt, or any portion thereof, “NORTH  AMERICAN HOLDINGS” will assume this debt is valid.  If you are disputing  this debt, you must notify our office in writing within 30 days from the above  mentioned date.  Our office will provide to you any information supplied to us by  our client in order to resolve this matter under a voluntary arrangement.  We will  also supply you with the name of the original creditor, if it is different from the  current creditor. (emphasis not added)   12.  DEFENDANT is not registered in Nevada as a debt collection company.   13.  As a result of the acts and omissions of the DEFENDANT, PLAINTIFF has been  forced to hire counsel to prosecute this action and to incur attorney fees and costs.   14.  PLAINTIFF is informed and believes and therefore alleges that PLAINTIFF and  the class members may have also suffered damages in other ways and to other extents not  presently known to PLAINTIFF, and not specified herein.  PLAINTIFF reserves the right to  assert additional facts and damages not referenced herein, and/or to present evidence of the  same at the time of trial.  15.  PLAINTIFF repeats, re-alleges, and incorporates by reference, paragraphs 1  through 14 inclusive, above.   18.  A class action is superior for the fair and efficient adjudication of the class  members’ claims as Congress specifically envisioned class actions as a principal means of  enforcing the FDCPA. See 15 U.S.C.§ 1692k.  The members of the class are generally  unsophisticated consumers, whose rights will not be vindicated in the absence of a class action.  Prosecution of separate actions by individual members of the classes would also create the risk  of inconsistent or varying adjudications resulting in the establishment of inconsistent or varying  standards and would not be in the best interest of judicial economy.    19.  If facts are discovered to be appropriate, PLAINTIFF will seek to certify the  class under Rule 23(b)(3) of the Federal Rules of Civil Procedure.  20.  PLAINTIFF repeats, re-alleges, and incorporates by reference, paragraphs 1  through 19 inclusive, above.   22.  DEFENDANT’S letter states in pertinent part:  Unless you notify this office within (30) thirty days after receiving this notice that  you dispute the validity of this debt, or any portion thereof, "NORTH  AMERICAN HOLDINGS" will assume this debt is valid.  If you are disputing  this debt, you must notify our office in writing within 30 days from the above  mentioned date.  Our office will provide to you any information supplied to us by  our client in order to resolve this matter under a voluntary arrangement.  We will  also supply you with the name of the original creditor, if it is different from the  current creditor. (emphasis not added).   23.  The collection letter improperly notifies the consumer that s/he must dispute the  debt in writing.  See Comacho vs. Bridgeport Financial, Inc. 430 F.3d 1078 (9th Cir. 2005).   The letter specifically states “[i]f you are disputing this debt, you must notify our office in  writing within 30 days from the above mentioned date.”    24.  Further, the collection letter implies that DEFENDANT will only provide  information from the creditor if the consumer enters into an agreement to resolve the debt,  rather than automatically upon receipt of the dispute notice.   26.  It has been necessary for PLAINTIFF to obtain the services of an attorney to  pursue this claim, on behalf of himself and those similarly situated, and is entitled to recover  reasonable attorneys’ fees therefor.  27.  PLAINTIFF repeats, re-alleges, and incorporates by reference, paragraphs 1  through 26 inclusive, above.   28.  PLAINTIFF’S Consumer Fraud claim is based on NRS 41.600 for violations of  NRS Chapter 598.   29.  At all times herein DEFENDANT was subject to the provisions of the Nevada  Deceptive Trade Practices Act; NRS 598.   30.  Pursuant to NRS 598.0923:  “A person engages in a ‘deceptive trade practice’  when in the course of his business or occupation he knowingly: 1. Conducts the business or  occupation without all required state, county or city licenses. …”   31.  Pursuant to NRS 649.075, as a collection agency operating in Nevada,  DEFENDANT was and is required to obtain a license to operate as a collection agency, issued  by the Nevada Department of Financial Institutions.   33.  DEFENDANT is not currently, and at all material times was not licensed as a  collection agency in Nevada and has not registered as a foreign collection agency in Nevada  and, as a result, DEFENDANT has violated the Nevada Deceptive Trade Practices Act.   34.  DEFENDANT is subject to liability for damages, as well as PLAINTIFF’S  attorney fees and costs pursuant to NRS 41.600 for violations of the Nevada Deceptive Trade  Practices Act and PLAINTIFF and the class members are entitled to damages as set forth in the  Prayer for Relief herein.     35.  It has been necessary for PLAINTIFF to obtain the services of an attorney to  pursue this claim, on behalf of himself and those similarly situated, and is entitled to recover  reasonable attorneys’ fees therefor.  9.  PLAINTIFF repeats, re-alleges, and incorporates by reference, paragraphs 1  through 8 inclusive, above.    VIOLATIONS OF THE FDCPA 15 U.S.C. § 1692g(a)  BROUGHT BY PLAINTIFF INDIVIDUALLY AND ON BEHALF OF  CLASS NUMBER ONE   VIOLATION OF THE NEVADA DECEPTIVE TRADE PRACTICES ACT  AGAINST DEFENDANT BY PLAINTIFF INDIVIDUALLY AND ON BEHALF OF  CLASS NUMBER TWO   