 This Action is properly maintained as a class action. The Class is initially defined  as:   All New Jersey consumers who were sent letters and/or notices from AUDIT  SYSTEMS concerning a debt owed to PERSONAL SUPPORT MEDICAL  SUPPLIERS, which included the alleged conduct and practices described  herein.   The class definition may be subsequently modified or refined.     The Class period begins one year to the filing of this Action.     Plaintiff is at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. § 1692a(3).    At some time prior to May 10, 2017, Plaintiff allegedly incurred a financial  obligation to PERSONAL SUPPORT MEDICAL SUPPLIERS.    The PERSONAL SUPPORT MEDICAL SUPPLIERS obligation arose out of a  transaction, in which money, property, insurance or services, which are the subject of the  transaction, are primarily for personal, family or household purposes.    The PERSONAL SUPPORT MEDICAL SUPPLIERS obligation did not arise out  of a transaction that was for non-personal use.    The PERSONAL SUPPORT MEDICAL SUPPLIERS obligation is a "debt" as  defined by 15 U.S.C. § 1692a(5).    PERSONAL SUPPORT MEDICAL SUPPLIERS is a "creditor" as defined by 15  U.S.C. § 1692a(4).    On or before May 10, 2017, the PERSONAL SUPPORT MEDICAL SUPPLIERS  obligation was sent to AUDIT SYSTEMS for the purpose of collection.    At the time the PERSONAL SUPPORT MEDICAL SUPPLIERS obligation was  sent to AUDIT SYSTEMS the PERSONAL SUPPORT MEDICAL SUPPLIERS obligation was  past due.    At the time the PERSONAL SUPPORT MEDICAL SUPPLIERS obligation was  sent to AUDIT SYSTEMS the PERSONAL SUPPORT MEDICAL SUPPLIERS obligation was  in default pursuant to the terms of the agreement creating the obligation and/or by operation of  law.    Defendants caused to be delivered to Plaintiff a letter dated May 10, 2017, which  was addressed to Plaintiff.  A copy of said letter is annexed hereto as Exhibit A, which is fully  incorporated herein by reference.    The May 10, 2017 letter was sent to Plaintiff in connection with the collection of  the PERSONAL SUPPORT MEDICAL SUPPLIERS obligation.     The May 10, 2017 letter is a “communication” as defined by 15 U.S.C. §  1692a(2).    The May 10, 2017 letter is the initial written communication sent from Defendant  to the Plaintiff.    The May 10, 2017 letter contained the Defendant’s contact information at the top  of the letter:   Collection letters and/or notices, such as those sent by Defendants, are to be  evaluated by the objective standard of the hypothetical “least sophisticated consumer.”    The May 10, 2017 letter fails to properly inform the least sophisticated consumer  that to effectively dispute the alleged debt, such dispute must be in writing.    The least sophisticated consumer upon reading the May 10, 2017 letter would be  confused as to what he or she must do to effectively dispute the alleged debt.     The least sophisticated consumer wishing to dispute the alleged debt would be  confused as to what steps he or she should take to notify Defendants of his or her dispute.    The least sophisticated consumer upon reading the instructions in the May 10,  2017 letter would be misled into believing that if he or she wished to effectively dispute the  alleged debt or any portion thereof, he or she may: (1) notify AUDIT SYSTEMS by calling the  toll free telephone number provided of (800) 741-1969, between during the business hours  Monday through Thursday 8:00 am - 9:00 pm  EST, or on Friday between 8:00am - 7:00pm  EST; or (2) write to AUDIT SYSTEMS at the address listed on the letter.    AUDIT SYSTEMS' instructions in the May 10, 2017 letter would cause least  sophisticated consumer to be unsure as to what he or she must do to effectively dispute the  alleged debt.    A dispute of a debt, to be effective, in the Third Circuit, must be in writing.  Graziano v. Harrison, 950 F.2d 107, 112 (3d Cir. 1991). Caprio v. Healthcare Revenue  Recovery Group, 709 F.3d 142 (3d Cir. March 1, 2013).      AUDIT SYSTEMS violated 15 U.S.C. §1692e(10) by falsely representing and  misleading Plaintiff into believing that if he wished to dispute the alleged debt or any portion  thereof, that he may (1) notify AUDIT SYSTEMS by calling the toll free telephone number  provided of (800) 741-1969, between during the business hours Monday through Thursday 8:00  am - 9:00 pm  EST, or on Friday between 8:00am - 7:00pm EST; or (2) write to AUDIT  SYSTEMS at the address listed on the letter.     The May 10, 2017 letter is misleading because the instructions can be read to  have two or more meaning, which one is inaccurate.     The May 10, 2017 letter can be read to mean that the least sophisticated consumer  may dispute the alleged debt by calling AUDIT SYSTEMS at the toll free telephone number  provided of (800) 741-1969, between during the business hours Monday through Thursday 8:00  am - 9:00 pm  EST, or on Friday between 8:00am - 7:00pm EST.    Congress enacted the FDCPA in part to eliminate abusive debt collection  practices by debt collectors.    Plaintiff and others similarly situated have a right to free from abusive debt  collection practices by debt collectors.    Plaintiff and others similarly situated have a right to receive proper notices  mandated by the FDCPA.    Plaintiff and others similarly situated were sent letters, which would have affected  their decision-making with regard to the debt.    Plaintiff has suffered damages and other harm as a direct result of AUDIT  SYSTEMS actions, conduct, omissions and violations of the FDCPA described herein.  WHEREFORE, Plaintiff demands judgment against Defendants as follows:  (a)  Declaring that this action is properly maintainable as a Class Action and  certifying Plaintiff as Class representative and the attorney(s), Joseph K. Jones, Esq., as Class  Counsel;  (b)  Awarding Plaintiff and the Class statutory damages;  (c)  Awarding Plaintiff and the Class actual damages;  (d)  Awarding pre-judgment interest;  (e)  Awarding post-judgment interest.  (f)  Awarding Plaintiff costs of this Action, including reasonable attorneys'  fees and expenses; and  (g)  Awarding Plaintiff and the Class such other and further relief as the Court  may deem just and proper.  Dated: November 15, 2017  s/ Joseph K. Jones   Joseph K. Jones, Esq.   FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §   1692 et seq.  VIOLATIONS   