[brief] In Point I, we address Defendant’s standing challenge.  POINT I.  Plaintiff Has Standing to Seek Statutory Damages for Defendant’s Violation of the FDCPA.  Defendant argues the lack of actual damages means Plaintiff lacks standing.  But actual damages are not an element of an FDCPA claim.  Cf. Midland Funding LLC v. Thiel, 446 N.J. Super. 537, 549 (App. Div. 2016) (listing the elements).  In the absence of actual damages, Plaintiff may recover “additional” (15 U.S.C. § 1692k(a)(2)) or statutory damages up to $1,000, as well as an award of attorney’s fees (15 U.S.C. § 1692k(a)(3)).  *Phillips v. Asset Acceptance, L.L.C.*, 736 F.3d 1076, 1083 (7th Cir. 2013) (“Proof of injury is not required when the only damages sought are statutory. ”); *Gonzales v. Arrow Fin. Serv., L.L.C.*, 660 F.3d 1055, 1067 (9th Cir. 2011) (“Statutory damages under the FDCPA are intended to ‘deter violations by imposing a cost on the defendant even if his misconduct imposed no cost on the plaintiff’”); see also National Consumer Law Center, *Fair Debt Collection* § 11.9.4 (10th ed. 2022) (updated at www.nclc.org/library) (collecting cases).  Statutory damages under the FDCPA, like nominal damages for certain common law torts, is “premised upon the wrong itself. ”  *Nappe v. Anschelewitz, Barr, Ansell & Bonello*, 189 N.J. Super. 347, 354 (App. Div. 1983).  Thus, when a debt collector engages in practices proscribed by the FDCPA, “those practices would themselves constitute a concrete injury. ”  *Bock v. Pressler & Pressler, LLP*, 254 F. Supp. 3d 724, 736 (D.N.J. 2017) (quoting an unpublished decision).  The reason is the FDCPA is “primarily self-enforcing; consumers who have been subjected to collection abuses will be enforcing compliance. ”  S. Rep. 95-382 (1977) at *5, 1977 U.S.C.C.A.N. 1695 at 1699 (hereinafter, “Senate Report”) (emphasis added).  The Second Circuit explained:  [T]he FDCPA enlists the efforts of sophisticated consumers like Jacobson as “private attorneys general” to aid their less sophisticated counterparts, who are unlikely themselves to bring suit under the Act, but who are assumed by the Act to benefit from the deterrent effect of civil actions brought by others.  *Jacobson v. Healthcare Fin. Servs.*, 516 F.3d 85, 91 (2d Cir. 2008).  For example, a consumer who received but did not read a misleading collection letter may still recover statutory damages.  *Bartlett v. Heibl*, 128 F.3d 497, 499 (7th Cir. 1997).  Moreover, recovery of attorney’s fees is mandatory even if no statutory damages are awarded.  *Graziano v. Harrison*, 950 F.2d 107, 113 (3d Cir. 1991) (“courts have required an award of attorney’s fees even where violations were so minimal that statutory damages were not warranted. ”)  When the U.S. Supreme Court redefined a case-or-controversy to exclude claims where the only harm is the invasion of a statutory right, the dissent observed, “The Court does not prohibit Congress from creating statutory rights for consumers; it simply holds that federal courts lack jurisdiction to hear some of these cases. ”  *TransUnion LLC v. Ramirez*, 594 U.S. 413, 459 n.9 (2021) ([...], dissenting).  Hence, “state courts [such as New Jersey courts] will exercise exclusive jurisdiction over these sorts of class actions. ”  *Id.*; *Matter of Cong. Dists. by N.J. Redist’g Com’n*, 249 N.J. 561, 570 (2022) (jurisdiction not limited to a case or controversy).  For these reasons, Plaintiff has standing to assert his FDCPA claims.