102.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.  103.  Count I is brought on behalf of all Plaintiffs.  104.  Exhibits A-D include a settlement offer that is misleading as to whether the debt  collector may revoke the offer of settlement at any time.  105.  Exhibits A-D effectively threaten to revoke the settlement offers at any time and  without notice even though neither Enhanced nor the creditor intended to revoke these offers.  106.  Defendant violated 15 U.S.C. §§ 1692e, 1692e(5), 1692e(10), and 1692f.  11.  On or around September 14, 2017, Enhanced mailed a debt collection letter to  Plaintiff Voeks regarding an alleged debt owed to “AT&T.”  A copy of this letter is attached to  this complaint as Exhibit A.   112.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.  113.  Count III is brought on behalf of Plaintiff Dombrowski.  114.  Exhibits C & D include contradictory deadlines as to the expiration of the  validation notice and thus the representations included Exhibit C and/or Exhibit D are false,  deceptive, and misleading as to such deadlines.  115.  Defendant violated 15 U.S.C. §§ 1692e, 1692e(10), 1692f, and 1692g(b)  12.  Upon information and belief, the alleged debt referenced in Exhibit A was  incurred for telecommunications services used only for personal, family, or household purposes.    13.  Upon information and belief, Exhibit A is a form letter, generated by a computer,  and with the information specific to Plaintiff Voeks inserted by the computer.   14.  Upon information and belief, Exhibit A is a form debt collection letter, used by  Defendant to attempt to collect alleged debts.   16.  Exhibit A contains the statutory validation notice that the FDCPA, 15 U.S.C. §  1692g, requires debt collectors provide alleged debtors along with, or within five days of, the  initial communication:   17.  Exhibit A also contains the following settlement offers:   18.  Exhibit A states that Enhanced is “not obligated to renew these offers.”   19.  Exhibit A, however, does not provide an expiration upon which the settlement  offers listed under “Option 2” and “Option 3” would need to be renewed.   20.  In the absence of an expiration date, the unsophisticated consumer would  understand a statement that the debt collector is “not obligated to renew this offer,” to mean that  Enhanced could, and would, rescind the settlement offer at any time and without notice.   21.  Upon information and belief, the debtor can settle the account for the amounts  listed under Option 2” and “Option 3,” or less, at any time.   23.  While Exhibit A largely tracks this safe-harbor language, without an expiration  date for the settlement offers made under “Option 2” and “Option 3,” the language does not have  its intended effect.   24.  As a practical matter, the unsophisticated consumer is not an FDCPA lawyer.  She  does not know that the purpose of the statement that “we are not obligated to renew any offers  provided” is to make her “realize that there is a renewal possibility but that it is not assured.”   25.  Instead, where the debt collector states that it is not obligated to renew an offer  but does not include an expiration date by which payment must be made, the unsophisticated  consumer would understand the safe-harbor language to mean that the offer was subject to  revocation.   26.  The unsophisticated consumer may even believe that the law requires a debt  collector to include the Seventh Circuit’s safe-harbor language if it will rescind the offer.   27.  Without an expiration date, the unsophisticated consumer would interpret a debt  collector’s statement that it is “not obligated to renew” as an implied threat to revoke the  settlement offer at any time and without notice.   29.  The safe-harbor language used in Exhibit A was created specifically for cases  where a debt collection letter stated a settlement date certain.  Without a date certain, the  language is false, deceptive, misleading, and confusing, and gives rise to FDCPA liability. Al v.  Van Ru Credit Corp., No. 17-CV-1738-JPS, 2018 U.S. Dist. LEXIS 70321 (E.D. Wis. Apr. 26,  2018).   31.  The unsophisticated consumer, not knowing when the settlement offer expired,  would feel intimidated into paying.  Muha v. Encore Receivable Mgmt., 558 F.3d 623, 629 (7th  Cir. 2009) (“Confusing language in a dunning letter can have an intimidating effect by making the  recipient feel that he is in over his head and had better pay up rather than question the demand for  payment.”).   32.  Moreover, providing the settlement offer alongside the validation notice  contradicts and overshadows the consumer’s validation rights.   33.  The settlement offer in Exhibit A is confusing to the unsophisticated consumer  because it requires that the consumer tender a payment within the validation period or shortly  thereafter, but does not explain how the validation notice and settlement “deadline” fit together.  Bartlett v. Heibl, 128 F.3d 497, 500 (7th Cir. 1997) (“In the typical case, the letter both demands  payment within thirty days and explains the consumer’s right to demand verification within  thirty days. These rights are not inconsistent, but by failing to explain how they fit together the  letter confuses.”).   34.  The unsophisticated consumer, unsure when the settlement offer in Exhibit A  expires, would feel compelled to make a settlement payment as soon as possible, and during the  validation period, to ensure the settlement offer had not expired without notice prior to her  tendering of payment.  Thus, there is an apparent contradiction between the settlement offer and  the validation notice.   36.  The unsophisticated consumer would not know whether requesting verification of  the debt would be interpreted as a rejection of the settlement offer.   37.  The plain language of Exhibit A is unclear as to how the debt collector would  proceed in the event that the consumer mailed a dispute along with a payment that was intended  to accept the settlement offer in the case that the debt could be verified.   38.  Where a consumer mailed a dispute along with a payment that was intended to  accept a settlement offer in Exhibit A, under the terms of Exhibit A, the debt collector might:   a. Hold the payment in escrow pending verification of the debt;  b. Interpret the payment as an accord and satisfaction and settlement in full that  contractually bars the consumer from requesting verification of the debt; or  c. Send the payment back to the consumer pending verification of the debt, in which  case the consumer may no longer be able to settle the debt because the offer  would have expired while the debt collector was obtaining verification.   39.  Where a consumer mails a dispute along with a payment that was intended to  accept a settlement offer with an impending expiration date, whether the FDCPA requires a debt  collector to proceed along any of the above paths is an open question in the Seventh Circuit.  See  Bailey v. TRW Receivables Management Services, Inc., 1990 U.S. Dist. LEXIS 19638, *7-8 (D.  Haw. Aug. 16, 1990) (“There is nothing in the statute which indicates that a debt collector is not  required to provide verification where a consumer requests it after paying the debt.”).    41.  The unsophisticated consumer would be confused as to whether she had  effectively exercised her validation rights by sending a payment along with a dispute letter.   42.  The unsophisticated consumer may unwittingly reject a settlement offer by  tendering the settlement payment along with her dispute letter.  If the debt collector treated the  acceptance of a settlement offer as a continuing attempt to collect a debt, see Sambor, 183 F.  Supp. 2d at 1243, the debt collector would need to return the settlement payment pending  verification of the debt.   43.  Because the debt collector may be legally obligated to return the consumer’s  settlement payment pending verification of the debt, the expiration date would lapse before the  consumer had effectively made the settlement payment.  By the time the debt collector verified  the debt, the consumer would have missed her chance to settle the debt even though she  attempted to tender a payment before the expiration date.   44.  Moreover, the unsophisticated consumer would have no idea how to both seek  verification of the debt and preserve the settlement offer in Exhibit A.   45.  The consumer needs time to process the information contained in an initial debt  collection letter before deciding whether to dispute, pay or take other action. This is the point of  the 30 day period in 15 U.S.C. 1692g(a).  See Jacobson v. Healthcare Fin. Servs., 516 F.3d 85,  95 (2d Cir. 2008) (“the aim of § 1692g is to provide a period for the recipient of a collection  letter to consider her options.”).   47.  The § 1692g validation period lasts for 30 days. It is the consumer’s right to  request verification until the end of the thirty day period.  If the request is not made until the end  of the thirty day period, the verification request would not be processed, researched by the  creditor, and returned to the consumer until long after settlement offer payment deadline has  expired.  The consumer would be left with no time to review the verification and determine  whether to accept the settlement offer.   48.  The unsophisticated consumer would have no idea how to both seek verification  of the debt and preserve the settlement offers in Exhibit A.  The unsophisticated consumer would  believe that the settlement offer would expire before the debt collector provides verification and  would be left with little or no time to review the verification and determine whether to accept the  settlement offer.   49.  The effect of the settlement offer in the initial written debt communication is to  discourage or prevent consumers from exercising their validation rights.   50.  Defendant did not include explanatory language in Exhibit A, see, eg. Bartlett,  128 F.3d 497, 501-02 (7th Cir. 1997).    51.  Any explanatory language should make clear whether a dispute will extend the  settlement offer while the debt collector is in the process of complying with its obligation to  verify the debt.   53.  In the context of credit reporting, there is a difference between resolving an  account by paying the account in full and resolving the account by settling it in full.  The  unsophisticated consumer would be confused as to whether the account would be reported as  “paid in full” or “settled in full.”  See e.g., Molton v. Experian Info. Solutions, Inc., 2004 U.S.  Dist. 659, at *13 (N.D. Ill. Jan. 21, 2004); Nielsen v. E*Trade Mortg. Corp., 2015 U.S. Dist.  LEXIS 39781, at *4-5 (E.D. Mich. Mar. 30, 2015); Shaw v. Experian Info. Solutions, Inc., 2016  U.S. Dist. LEXIS 134991, at *31-32 (S.D. Calif. Sept. 28, 2016); Keller v. Trans Union LLC,  2017 U.S. Dist. LEXIS 283, at *7-8 (D. Ariz. Jan. 3, 2017).   54.  Upon information and belief, the offer to “reduce your outstanding balance”  stated in Exhibit A is mere a settlement offer, not a “reduced balance” by which the consumer  may pay the account in full.   55.  Upon information and belief, if the consumer paid the “full reduced balance  amount,” Enhanced, and/or the creditor, would report the account to consumer reporting  agencies as “settled in full” rather than “paid in full.”   56.  Upon information and belief, Enhanced uses the phrase “reduce your outstanding  balance”  to confuse consumers and induce them into paying this amount under the assumption  that Convergent, and the creditor, will report the account to consumer reporting agencies as “paid  in full.”    57.  Plaintiff Voeks was deceived, misled, and confused by Exhibit A.   59.  On or about November 16, 2017, Enhanced mailed a debt collection letter to  Plaintiff Maniaci regarding an alleged debt owed to “AT&T.”  A copy of this letter is attached to  this complaint as Exhibit B.   60.  Upon information and belief, the alleged debt referenced in Exhibit B was  incurred for telecommunications services used only for personal, family, or household purposes.    61.  Upon information and belief, Exhibit B is a form letter, of the same form as  Exhibit A, and with the information specific to Plaintiff Maniaci inserted by computer.   62.  Upon information and belief, Exhibit B is the first written communication that  Defendant sent to Plaintiff Maniaci regarding the alleged debt to which Exhibit B refers.   63.  Exhibit B contains the statutory validation notice that the FDCPA, 15 U.S.C. §  1692g, requires debt collectors provide alleged debtors along with, or within five days of, the  initial communication:   64.  Exhibit B also contains the following settlement offer:   65.  Exhibit B states that Enhanced is “not obligated to renew these offers.”   67.  Moreover, providing the settlement offer alongside the validation notice  contradicts and overshadows the consumer’s validation rights.   68.  Moreover, the representation of the settlement amounts as a means for the  consumer to “reduce your outstanding balance” is likewise false, deceptive, and misleading.   69.  Plaintiff Maniaci was deceived, misled, and confused by Exhibit B.   70.  The unsophisticated consumer would be deceived, misled, and confused by  Exhibit B.   Facts Related to Plaintiff Dombrowski   71.  On or about October, 2017, Enhanced mailed a debt collection letter to Plaintiff  Dombrowski regarding an alleged debt owed to “AT&T.”  A copy of this letter is attached to this  complaint as Exhibit C.   72.  Upon information and belief, the alleged debt referenced in Exhibit C was  incurred for telecommunications services used only for personal, family, or household purposes.    73.  Upon information and belief, Exhibit C is a form letter, of the same form as  Exhibits A-B, and with the information specific to Plaintiff Dombrowski inserted by computer.   74.  Upon information and belief, Exhibit C is the first written communication that  Defendant sent to Plaintiff Dombrowksi regarding the alleged debt to which Exhibit C refers.   76.  Exhibit C also contains the following settlement offer:   77.  Exhibit C states that Enhanced is “not obligated to renew these offers.”   78.  Exhibit C, however, does not provide an expiration upon which the settlement  offers listed under “Option 2” and “Option 3” would need to be renewed.   79.  Moreover, providing the settlement offer alongside the validation notice  contradicts and overshadows the consumer’s validation rights.   80.  Moreover, the representation of the settlement amounts as a means for the  consumer to “reduce your outstanding balance” is likewise false, deceptive, and misleading.   81.  On or about February 14, 2018, Enhanced mailed another debt collection letter to  Plaintiff Dombrowski regarding the same alleged “AT&T” debt.  A copy of the letter is attached  to this complaint as Exhibit D.   82.  Upon information and belief, the letter in Exhibit D is also a form letter, generated  by computer, and with the information specific to Plaintiff Dombrowski inserted by computer.   83.  Upon information and belief, the letter in Exhibit D is also a form debt collection  letter used by Enhanced to attempt to collect the alleged debt.   84.  Just as Exhibit D, Exhibit C lists the “Amount of Debt” as $407.92 and lists an  “Account Number” ending in “9879.”   85.  Exhibit D also includes the following settlement offer:   87.  Exhibit D, however, does not provide an expiration upon which the settlement  offers would need to be renewed.   88.  Additionally, Exhibit D also contains the following debt validation notice:   89.  Exhibit C and Exhibit D thus give conflicting deadlines.    90.  Additionally, as previously stated, by providing the settlement offer without an  expiration date in combination with the statement “we are not obligated to renew this offer,” the  unsophisticated consumer would understand that the offer could be revoked at any time, without  notice, prior to the expiration of the validation period.   91.  The settlement offer in Exhibit D thus contradicts and overshadows the  consumer’s validation rights.   92.  Plaintiff Dombrowski was confused by both Exhibit C and Exhibit D.   93.  The unsophisticated consumer would be confused by Exhibit C and Exhibit D.    The FDCPA   96.  15 U.S.C. § 1692e generally prohibits a debt collector from using “any false,  deceptive, or misleading representation or means in connection with the collection of any debt.”   97.  15 U.S.C. § 1692e(5) specifically prohibits debt collectors from making a “threat  to take any action that cannot legally be taken or that is not intended to be taken.”   98.  15 U.S.C. § 1692e(10) specifically prohibits the “use of any false representation  or deceptive means to collect or attempt to collect any debt.”   Facts Relating to Plaintiff Voeks  