 Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).    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 collect and/or  have purchased debts.    Excluded from the Plaintiff Class are the Defendants and all officer, members,  partners, managers, directors and employees of the Defendants and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate  families.     There are questions of law and fact common to the Plaintiff Class, 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  Exhibit A, violate 15 U.S.C. §§ l692e, 1692f.    The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiff will fairly and adequately protect the interests of the  Plaintiff Class defined in this complaint. The Plaintiff has retained counsel with experience in  handling consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiff  nor his attorneys have any interests, which might cause them not to vigorously pursue this action.    Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Class predominate over any questions affecting an individual member, and a class action is  superior to other available methods for the fair and efficient adjudication of the controversy.    Depending on the outcome of further investigation and discovery, Plaintiff 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).   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.    Some time prior to May 13, 2020 an obligation was allegedly incurred to a creditor.    The obligation arose out of transactions in which money, property, insurance or  services, which are the subject of the transactions, were primarily for personal, family or  household purposes.    The alleged obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).    Defendant Midland Credit purportedly purchased the alleged debt and is currently  collecting the alleged debt.    On or about March 13, 2020, Defendant Midland Credit sent Plaintiff a collection  letter (the “Letter”) regarding the alleged debt owed. See Exhibit A.    The letter states a total balance of $12,889.53.    The letter further provides a settlement offer of $10,319.62 which expires on  6/12/2020.    The letter further states in part: “A judgment could be awarded by the court before  the expiration of the discount offer listed in this letter.  A judgment may include costs and post- judgment interest which may increase the balance owed. If you pay the discount offer in this  letter by 06/12/2020, we will satisfy the judgment in full upon receipt of payment based on the  balance stated in this letter.”    The letter states that if the discount offer is paid by 6/12/2020, Defendant will satisfy  the judgment in full “based on the balance stated in this letter.”    This statement is confusing and deceptive because it implies that the payment will  only satisfy the judgment based on the balance stated in the letter, which is $12,889.53 and not  if the balance rises which Defendant’s letter indicates may happen (“A judgment may include  costs and post-judgment interest which may increase the balance owed.”)    Alternatively, the letter could be read to mean that payment of the discounted amount  will satisfy the debt entirely, whether or not the balance increases due to costs and post-judgment  interest.    In addition, the letter is misleading and deceptive by alluding to a possible judgment  without referencing any actual case and whether an actual lawsuit that could lead to a judgment  currently exists.     Furthermore, the letter discusses the judgment in extremely speculative terms, stating  that a judgment “could” be awarded and “may” include costs, when, upon information and  belief, the Defendant knows whether its legal counsel plan on filing for judgment and the  speculation is intended only to frighten and harass the Plaintiff to make an immediate payment.     Defendant's collection efforts with respect to this alleged debt from Plaintiff caused  Plaintiff to suffer concrete and particularized harm because the FDCPA provides Plaintiff with  the legally protected right to be not to be misled or treated unfairly with respect to any action  for the collection of any consumer debt.    Defendant's deceptive, misleading and unfair representations with respect to its  collection effort were material misrepresentations that affected and frustrated Plaintiff's ability  to intelligently respond to Defendant's collection efforts because Plaintiff could not adequately  respond to the Defendant's demand for payment of this debt.    Defendant’s actions created an appreciable risk to Plaintiff of being unable to  properly respond or handle Defendant’s debt collection.    Plaintiff was confused and misled to her detriment by the statements in the dunning  letter, and relied on the contents of the letter to her detriment.    Plaintiff would have pursued a different course of action were it not for the statutory  violation.    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.    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.    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.    Defendant violated § 1692e:   a. As the Letter it is open to more than one reasonable interpretation, at least one of  which is inaccurate.  b. By making a false and misleading representation in violation of §1692e(10).    By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, and Plaintiff is entitled to an award of  actual damages, statutory damages, costs and attorneys’ fees.   Plaintiff repeats the above paragraphs as if set forth here.    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. § 1692f.    Defendant violated this section by   a. Using threatening and harassing language regarding the possible judgments.    By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692f et seq. of the FDCPA and is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. § 1692f et seq.  