20.  On or about February 9, 2018, Defendant sent an initial written  communication to Plaintiff in connection with the collection of the Debt.   21.  A true and correct copy of the February 9, 2018 written communication is  attached as Exhibit A.   22.  The February 9, 2018 communication was the first communication  Plaintiff received from Defendant in connection with the Debt.   23.  Plaintiff did not receive any additional written communications from  Defendant within five days of the February 9, 2018 communication.   24.  The February 9, 2018 communication advised Plaintiff that Defendant  represented Relocation Reps LLC (the “Relocation Reps”). See Ex. A.     26.  Critically, while the communication provides a principal balance, the  February 9, 2018 communication omits the amount of money due or allegedly due. Id.    27.  In fact, the February 9, 2018 communication states: “Please be advised  that your delinquency in the amount of $ which is owed to our client, RELOCATION  REPS LLC, is outstanding. This debt has been referred to us for collection. Accordingly,  demand is hereby made for full payment of our past due account.” Id.   28.  The February 9, 2018 communication then advised Plaintiff that “[i]n  order to resolve this matter, please remit payment in full” without identifying the amount  that Plaintiff is required to pay to resolve the matter. Id.   29.  The February 9, 2018 communication also contained an “Amount Due”  box that is blank.   30.  Plaintiff brings this action as a class action pursuant to Federal Rules of  Civil Procedure 23(a) and 23(b)(3) on behalf of a class consisting of:  All persons (a) with an Illinois address, (b) to whom Hunter Warfield,  Inc., (c) within one year before the date of this complaint, (d) in  connection with the collection of a consumer debt, (e) mailed an initial  debt collection communication not returned to Hunter Warfield, Inc. as  undeliverable (f) that (1) did not state the amount of the debt that is due or  allegedly due, or (2) stated “[p]lease be advised that your delinquency in  the amount of $ which is owed to our client….” but omitted an amount  after the dollar sign.   32.  The proposed class satisfies Rule 23(a)(1) because, upon information and  belief, it is so numerous that joinder of all members is impracticable.   33.  The exact number of class members is unknown to Plaintiff at this time  and can only be determined through appropriate discovery.    34.  The proposed class is ascertainable because it is defined by reference to  objective criteria.    35.  In addition, and upon information and belief, the names and addresses of  all members of the proposed class can be identified in business records maintained by  Defendant.     36.  The proposed class satisfies Rules 23(a)(2) and 23(a)(3) because  Plaintiff’s claims are typical of the claims of the members of the class.    37.  To be sure, the claims of Plaintiff and all members of the class originate  from the same conduct, practice and procedure on the part of Defendant, and Plaintiff  possesses the same interests and has suffered the same injuries as each member of the  proposed class.   38.  Plaintiff satisfies Rule 23(a)(4) because he will fairly and adequately  protect the interests of the members of the class and has retained counsel experienced and  competent in class action litigation.    39.  Plaintiff has no interests that are irrevocably contrary to or in conflict with  the members of the class that he seeks to represent.   41.  Furthermore, as the damages suffered by individual members of the class  may be relatively small, the expense and burden of individual litigation make it  impracticable for the members of the class to individually redress the wrongs done to  them.   42.  There will be no unordinary difficulty in the management of this action as  a class action.   43.  Issues of law and fact common to the members of the class predominate  over any questions that may affect only individual members, in that Defendant has acted  on grounds generally applicable to the class.    44.  Among the issues of law and fact common to the class are:  a. Defendant’s violations of the FDCPA as alleged herein;  b. Whether Defendant is a debt collector as defined by the FDCPA;  c. the availability of statutory penalties; and  d. the availability of attorneys’ fees and costs.  45.  Plaintiff repeats and re-alleges each and every factual allegation contained  in paragraphs 1 through 44.   47.  The February 9, 2018 communication does not set forth the amount of the  Debt. See Ex. A.   48.  Therefore, Defendant violated 15 U.S.C. § 1692g(a). See, e.g.,  Miller v. McCalla, Raymer, Padrick, Cobb, Nichols, and Clark, LLC, 214 F.3d 872, 875  (7th Cir. 2000) (“The statement does not comply with the Act (again we can find no case  on the question). The unpaid principal balance is not the debt; it is only a part of the debt;  the Act requires statement of the debt.”).    49.  The harm suffered by Plaintiff is particularized in that the violative  February 9, 2018 communication was sent to him personally, regarded his personal  obligation, and failed to give him statutorily-mandated disclosures to which he was  entitled.   51.  And the content of the February 9, 2018 communication created a material  risk of harm to the concrete interest Congress was trying to protect in enacting the  FDCPA. See, e.g., Zirogiannis v. Seterus, Inc., No. 17-140-cv, 2017 WL 4005008, at *2  (2d Cir. Sep. 12, 2017) (concluding “that the specific procedural violation alleged in the  amended complaint presents a material risk of harm to the underlying concrete interest  Congress sought to protect with the FDCPA”).    52.  Specifically, where a consumer is not told the amount of the Debt, he has  no way to assess whether the amount the debt collector says is owed is actually owed.  Dechert v. Cadle Co., No. IP01-880-C(B/G), 2003 WL 23008969, at *3 (S.D. Ind. Sept.  11, 2003) (“Consequently, with respect to the issue of its failure to identify the  total amount of the debt due and owing, the letter violates the FDCPA.”).    53.  In addition, Defendant’s actions invaded a specific private right created by  Congress, and the invasion of said right creates the risk of real harm. See Haddad v.  Midland Funding, LLC, 255 F. Supp. 3d 735, 739 (N.D. Ill. 2017).  PRACTICES ACT, 15 U.S.C. § 1692g(a)  