)    Defendants allege Plaintiff owes a debt (“the alleged Debt”).      The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of  a transaction in which the money, property, insurance, or services which are the subject of the  transaction are primarily for personal, family, or household purposes.    The alleged Debt does not arise from any business enterprise of Plaintiff.     The alleged Debt is a “debt” as defined by 15 U.S.C. § 1692a(5).     At an exact time known only to Defendants, the alleged Debt was assigned or  otherwise transferred to Defendants for collection.     At the time the alleged Debt was assigned or otherwise transferred to Defendants  for collection, the alleged Debt was in default.     In its efforts to collect the alleged Debt, Defendants contacted Plaintiff by email  (“the Email”) dated October 1, 2019. (A true and accurate copy is annexed hereto as “Exhibit    The Email conveyed information regarding the alleged Debt.    The Email is a “communication” as defined by 15 U.S.C. § 1692a(2).     The Email was the initial written communication Plaintiff received from  Defendants concerning the alleged Debt.    The Email was received and read by Plaintiff.    15 U.S.C. § 1692g protects Plaintiff's concrete interests. Plaintiff has the interest  and right to receive a clear, accurate and unambiguous validation notice, which allows a  consumer to confirm that he or she owes the debt sought to be collected by the debt collector. As  set forth herein, Defendants deprived Plaintiff of this right.    15 U.S.C. § 1692e protects Plaintiff's concrete interests. Plaintiff has the interest  and right to be free from deceptive and/or misleading communications from Defendants. As set  forth herein, Defendants deprived Plaintiff of this right.      15 U.S.C. § 1692g(b) provides if the consumer notifies the debt collector in  writing within the thirty-day period that the debt, or any portion thereof, is disputed, or that the  consumer requests the name and address of the original creditor, the debt collector shall cease  collection of the debt, or any disputed portion thereof, until the debt collector obtain verification  of the debt or a  copy of a judgment, or the name and address of the original creditor, is mailed to  the consumer by the debt collector.    15 U.S.C. § 1692e prohibits a debt collector from using any false, deceptive, or  misleading representation or means in connection with the collection of any debt.    15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.      Plaintiff disputed the alleged Debt by email on September 30, 2019.    In response to Plaintiffs dispute, a representative for Defendants contacted  Plaintiff by email, to notify her that the dispute would be filed immediately.      Additionally Defendants’ representative informed Plaintiff that they would be  reaching out to Plaintiff once they received adequate information from LVNV Funding LLC.    Defendants again contacted Plaintiff by the Email on October 1, 2019, luring her  into an offer for flexible payment options.    The Email further stated, that it was an attempt to collect a debt.    Defendants failed to respond to Plaintiffs dispute on the alleged Debt but instead  continued collection efforts on such alleged Debt.    As a result of the foregoing Defendants violated 15 U.S.C. § 1692g(b) by failing  to cease collection efforts after receiving Plaintiff’s written dispute on the alleged Debt.    As a result of the foregoing Defendants violated 15 U.S.C. § 1692e by falsely  representing that it was entitled to continue collection efforts and were not required to cease  communication after receiving such dispute from Plaintiff.    As a result of the foregoing Defendants violated 15 U.S.C. § 1692e(10) by  attempting to collect on the alleged Debt through false representation that such efforts were  legitimate.    Plaintiff brings this action individually and as a class action on behalf of all  persons similarly situated in the State of North Carolina.    Plaintiff seeks to certify a class of:  All consumers to whom Defendants sent a collection letter in  violation of 15 U.S.C. § 1692g(b), substantially and materially similar  to the Letter sent to Plaintiff, which letter was sent on or after a date  one year prior to the filing of this action to the present.    This action seeks a finding that Defendants' conduct violates the FDCPA, and  asks that the Court award damages as authorized by 15 U.S.C. § 1692k.    The Class consists of more than thirty-five persons.    Plaintiff's claims are typical of the claims of the Class. Common questions of law  or fact raised by this action affect all members of the Class and predominate over any individual  issues.  Common relief is therefore sought on behalf of all members of the Class. A class action is  superior to other available methods for the fair and efficient adjudication of this controversy.    The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of the  Class, and a risk that any adjudications with respect to individual members of the Class would, as  a practical matter, either be dispositive of the interests of other members of the Class not party to  the adjudication, or substantially impair or impede their ability to protect their interests.   Defendants have acted in a manner applicable to the Class as a whole such that declaratory relief  is warranted.    Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class is not extraordinarily difficult, and the factual and legal issues  raised by this action will not require extended contact with the members of the Class, because  Defendants' conduct was perpetrated on all members of the Class and will be established by  common proof.  Moreover, Plaintiff has retained counsel experienced in actions brought under  consumer protection laws. 