The attached complaint sets forth all of the claims involving the deceptive nature in which LVNV Funding , LLC brought its case under index # XXXX. Naming a plaintiff as " LVNV Funding , LLC XXXX XXXX XXXX '' is a deceptive practice because that entity misidentifies the creditor, is not licensed, lacks authority, and implies more of a direct relationship than exists between LVNV and XXXX XXXX. A federal case annexed to the attached complaint clearly states a cause of action for that tactic under the Fair Debt Collection Practices Act. XXXX XXXX challenges LVNV 's legal right to sue her in the first place. Upon information and belief, LVNV failed to secure a valid chain of assignments before it sued XXXX XXXX. New York courts are very concerned about debt buyers who do not and/or can not produce a valid chain of custody. 

XXXX XXXX also contends that LVNV added pre-judgment interest to her debt but it lacked contractual or statutory authority to do so. 

XXXX XXXX was not given valid notice of any assignment and any meaningful right to demand validation.