13. Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a)  and 23(b)(3).   14. The Class consists of (a) all individuals nationwide to whom Weltman, Weinberg & Reis  Co., LPA mailed a collection letter (b) in an attempt to collect an amount owed or allegedly  owed to SLM PRIVATE CREDIT STUDENT LOAN TRUST 2005-B  (c) which failed to  notify the recipient that interest, late fees, or other charges were accruing (d) 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.   15. The identities of all class members are readily ascertainable from the records of Defendants  and those companies and entities on whose behalf they attempt to collects and/or have  purchased debts.   17. There are questions of law and fact common to the Plaintiff Classes, which common issues  predominate over any issues involving only individual class members. The principal issue  is whether the Defendants’ written communications to consumers, in the forms attached as  Exhibits A, violate 15 U.S.C. §§ 1692e.   18. The Plaintiffs’ claims are typical of the class members, as all are based upon the same facts  and legal theories.   19. The Plaintiffs will fairly and adequately protect the interests of the Plaintiff Classes defined  in this complaint. The Plaintiffs have retained counsel with experience in handling  consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiffs nor  their attorneys have any interests, which might cause them not to vigorously pursue this  action.   22. Depending on the outcome of further investigation and discovery, Plaintiffs 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).  23. 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.   24. Some time prior to November 03, 2016, an obligation was allegedly incurred to SLM  40. 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.   41. 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.   42. Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.     43. Defendant violated said section by:   Falsely representing the amount of the debt in violation of §1692e(2)   Making a false and misleading representation in violation of §1692e(10).   44. 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.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e et seq.  