Sometime before May 15, 2017, Plaintiff is alleged to have incurred certain  financial obligations to the City of Tempe Utilities.   These financial obligations were primarily for personal, family or household  purposes and are therefore a “debt” as that term is defined by 15 U.S.C.  §1692a(5).   Sometime thereafter, but before May 15, 2017, Plaintiff allegedly fell behind  and defaulted on the payments allegedly owed on the alleged debt.   Subsequently, but before May 15, 2017, City of Tempe assigned, placed, or  otherwise transferred the alleged debt to VCS for collection.   On or about May 15, 2017, Defendant sent Plaintiff a letter attempting to  collect the alleged debt.   In Defendant’s May 15, 2017 letter to Plaintiff, the language of which  overshadowed, weakened, and failed to comply with, the notice required by  15 U.S.C. § 1692g(a), because it attempted to limit the rights available to  Plaintiff in a manner that creates a contradiction would confuse the least  sophisticated consumer into disregarding his or her rights pursuant to the  validation notice required in 15 U.S.C. § 1692g by stating:  The above account has been assigned to this office for  collection. Please remit payment in full of the current balance to  this office in resolution of this matter. If this debt is not paid  within 30 days from your receipt of this notice, we may  exercise various options to enforce collection activity, including  the reporting of this debt to credit reporting agencies…   The deadline imposed by Defendant as well as their threat enforce collection  activity are misleading as it does not account for Plaintiff’s ability to dispute  the debt and to request verification and/or validation pursuant to 1692g,  which would halt all collection activity pursuant to 15 U.S.C. § 1692g(b).    The purpose for this confusing language was to limit the rights available to  Plaintiff in a manner that creates a contradiction that would confuse the least  sophisticated consumer into disregarding his or her rights pursuant to the  validation notice required in 15 U.S.C. § 1692g.   This conduct was a false, deceptive, or misleading representation or means in  connection with the collection of the alleged debt.  As such, this action by  Defendant violated 15 U.S.C. §§ 1692e and 1692e(10).   Through this conduct, Defendant used an unfair or unconscionable means to  collect or attempt to collect any debt.  Consequently, Defendant violated 15  U.S.C. § 1692f.  Plaintiff bring this action on her own behalf, and on behalf of all others  similarly situated.   This action pleads the following class action allegations.  Plaintiff defines “The Class” as (i) all persons with addresses  within the state of Arizona; (ii) who were sent an initial  collection letter, which was similar or identical to Defendant’s  May 15, 2017 to Plaintiff; (iii) to recover a consumer debt; (iv)  which were not returned undelivered by the United States  Postal Service. The class period is one year prior to the filing of  this Complaint.   For purposes of the FDCPA Claim, the class period is one year prior to the  filing of the original Complaint.   There are more than 40 members of the class, and the class members are so  numerous that joinder is impracticable.   The individual identities of the individual members are ascertainable through  Defendants’ records or by public notice.   There is a well-defined community of interest in the questions of law and fact  involved affecting the members of the Class.  The questions of law and fact  common to the Class predominate over questions affecting only individual  class members, and include, but are not limited to, the following:  A) Whether Defendants violated the FDCPA;  B) Whether members of the Class are entitled to the remedies under the  Plaintiff repeats, re-alleges, and incorporates by reference, all other  paragraphs.   The foregoing acts and omissions constitute numerous and multiple violations  of the FDCPA, including but not limited to each and every one of the above- cited provisions of the FDCPA, 15 U.S.C. § 1692 et seq.   As a result of each and every violation of the FDCPA, Plaintiff is entitled to  any actual damages pursuant to 15 U.S.C. § 1692k(a)(1); statutory damages in  an amount up to $1,000.00 pursuant to 15 U.S.C. § 1692k(a)(2)(A); and,  reasonable attorney’s fees and costs pursuant to 15 U.S.C. § 1692k(a)(3) from  Defendant.  FAIR DEBT COLLECTION PRACTICES ACT (FDCPA)  15 U.S.C. §§ 1692 ET SEQ.  