The amount of the debt;    Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).    The Class consists of:   a. all individuals with addresses in the State of Texas;  b. to whom Defendant Law Offices sent an initial collection letter attempting to  collect a consumer debt;  c. on behalf of  Defendant Westhill;  d. that included a false and misleading statements regarding consumers rights to  dispute the debt as outlined in §1692g;  e. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (2l) days after the filing of this action.    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.     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 her attorneys have any interests, which might cause them not to vigorously pursue this  action.   The name of the creditor to whom the debt is owed;    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.    The MidAmerica Bank & Trust obligation arose out of transactions where Plaintiff  used MidAmerica Bank & Trust funds primarily for personal, family or household purposes.     The alleged MidAmerica Bank & Trust obligation is a "debt" as defined by 15  U.S.C.§ 1692a(5).    MidAmerica Bank & Trust is a "creditor" as defined by 15 U.S.C.§ 1692a(4).    Defendant Westhill, a debt collector and the subsequent owner of the MidAmerica  Bank & Trust debt, contracted with Defendant Law Offices to collect the alleged debt.    Defendants collect and attempt to collect debts incurred or alleged to have been  incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and internet.  Violation – September 25, 2017 Collection Letter    On or about September 25, 2017, Defendant Law Offices sent the Plaintiff an initial  contact notice (the “Letter”) regarding the alleged debt owed to Defendant Westhill. See Letter  at Exhibit A.   A statement that unless the consumer, within thirty days after receipt of  the notice, disputes the validity of the debt, or any portion thereof, the  debt will be assumed to be valid by the debt-collector;    This letter is commonly referred to as the “G notice.”    The “G-Notice” in the September 25, 2017 letter does not meet the required  guidelines of the FDCPA and falsely state the requirements of the consumer.    Firstly, the “G-Notice” wrongfully advises the consumer that she must “notify  [Defendants] in writing that she disputes the debt or Defendants will assume the debt to be  valid.”     This language is false and misleading to the Plaintiff since a consumer may dispute  the debt with Defendants by any method in order to be a valid dispute. (See §1692g(a)(3)).    Defendants letter then improperly advises the consumer as to her rights under  §1692g as when it fails to properly state  when notification in writing is required.    Defendants wrongfully advise the consumer that “if you notify us of a dispute, we  will obtain verification of the debt and mail a copy of such verification to you.”     Defendants’ letter fails on all accounts to inform the Plaintiff of her fundamental  rights as a consumer to dispute the debt, and the methods in which different disputes and  information requested must occur.    Plaintiff incurred an informational injury as Defendants falsely stated her rights  under §1692g of the FDCPA which put her at imminent risk of losing her right to validate and  dispute the debt.    As a result of Defendants’ deceptive, misleading and unfair debt collection practices,  Plaintiff has been damaged.   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.    Defendants’ 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.    Defendants violated §1692e :   a. By making a false and misleading representation in violation of §1692e(10).    By reason thereof, Defendants are liable to Plaintiff for judgment that Defendants’  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.   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.    Defendants’ 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. § 1692g.     Pursuant to 15 USC §1692g, a debt collector:  Within five days after the initial communication with a consumer in connection with  the collection of any debt, a debt collector shall, unless the following information is  contained in the initial communication or the consumer has paid the debt, send the consumer  a written notice containing –    The Defendants violated 15 U.S.C. §1692g, by wrongfully advising Plaintiff of her  rights and responsibilities as set forth in this section of the FDCPA.   A statement that, upon the consumer’s written request within the thirty- day period, the debt collector will provide the consumer with the name  and address of the original creditor, if different from the current creditor.     By reason thereof, Defendants are liable to Plaintiff for judgment that Defendants’  conduct violated Section 1692g et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  