Plaintiffs repeat, reiterate and incorporate the allegations contained in paragraphs numbered oo1" through"z3" herein with the same force and effect as if the same were set forth at length herein.  Upon information and belief, Defendants, on behalf of a third-party, began efforts to collect an alleged consumer debt from the Plaintiffs.  Upon information and belief, and better known to the Defendants, the Defendants began their collection efforts and campaign of communications with the Plaintiffs by calling their cell phones and leaving automated messages.  The calls would come in from numbers 407-732-2415,847-426-9203 and 2t0-520-64A0.  In response to these calls the Plaintiffcalled the Defendant Chase on May 25,20178nd was connected with a female representative  The Plaintiffgave the representative the last four digits of her credit card and verified her account. The Plaintiffthen asked for some infonnation on her account and informed the representative that she did not want to receive uriy *o.. calls from the Defendant.  After receiving the information she requested from the representative the call was then concluded.  In October of 2077 the PlaintiffJakob Padwa started receiving calls from the Defendant Chase as well to his cell phone number of 347-977'6613. The calls would come from the same mentioned numbers from Chase as the calls made to Miriam Padwa and he too would be left automated messages on his cell phone.  In response to the phone calls the Plaintiffcalled the Defendants on October 2, 2017 ardwas connected \rrith a male representative. The Plaintiffgave the representative the last four digits of his social security number to access his account.  The Plaintiffinformed the representative that he had two cards and the representative stated that he had located both accounts.  The Plaintiffstated that he would like the phone calls to stop and informed the 'representative that he would see what he could do about bringlng the account current.  The representative questioned when that would be and the Plaintiffsaid he would call back the next day. The Plaintiffthen resra*ted that he did not want to receive any more calls and the conversation was concluded.  ,$ince the conclusion of the call and the requests for the phone calls to cease, the Defendants continued to contact the Plaintifts. To date the Plaintiffs have received at least 200 calls to their cell phones.  Following the phone call;dated January ll,'2018 Plaintiff Miriam Padwa received a collection letter from Defendant Nationwide Credit lnc informing her that she owed $9,266.27, originally to Chase Bank USA NA.  The letter stated "Nationwide Credit lnc previously sent you a letter more than thirty (30) days ago, advising you that your past due account was placed with us for collection.  It then $4,262.48. This ofler or before 1124/2018. stated is valid "We are offering you an opportunity to settle this amount for . for a one-time payment of the settlement amount and is due on  However, towards the bottom of the letter it then states oolf we sefile this debt with you for less than the full outstanding balance. Chase may offer you less than favorable terms in the future for some Chase products or services or may deny you applications. "  A copy of the Defendant's collection letter is attached hereto as exhibit'.A".  Plaintiffs repeat, reiterate and incorporate the allegations contained in t- 'ii paragraphs numbered "1" through "45" herein with the same force and effect as if the same were set forth at length herein.   15 USC fi1692 e-preface states that a debt collEctor may not use false, deceptive or misleading representation or means in connection with the collection of any debt.   Defendants violated 15 USC $1692 e-preface when they sent out a collection letter dated January 11, 2018 and deceptively stated that if the Plaintiffchose to take the settlement offer and pay her debt for less than the flrll amount owed then she would possibly be in poor standing with the original creditor and have less favorable dealings with them in the future. Either Chase has a policy or providing less favorable terms for those who pay less than the full balance or they have a policy of providing the same favorable terms as those who are not in debt to them. Either way it is a misleading statement.  The threat of receiving less favorable terms is unfair, deceptive and misleading, as it is ambiguous and confusing, and forces the consumer to fear not paying the full amount to receive, as implied, urfavorable temrs. However, the letter again confuses and misleads the consumer to believe if she pays she will definitely receive favorable terms. Nowhere in the letter is it spelled out that paying the full balance will result in favorable terms.   As a result of Defendant's violations of the FDCPA, the Plaintiffhas been damaged and is entitled to damages in accordance with the FDCPA sECO"np cAUSE-gr ACTIO, N (Wolations of the TCPA)  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs numbered "l" through "53" herein with the same force and effect as if the same were set forth at length herein.  It is thus clear from the plain language of the TCPA, and its considerable body of resultant case law that the TCPA is violated when a cellular telephone is called with an automatic dialer without consent, even if no charges are alleged or incurred.   With the autodialed calls to Plaintiffs' telephones commencing on or about May 2017 and continuing at atate of approximately (200) times thereafter, the Defendants violated various provisions of the TCPA, including but not limited to 47 USC $227(b)(AXiii).  The Defendants, having been informed that Piaintiffs requested that no further calls be received, willfully violated the TCPA at least (200) tiles.  Pursuant to the TCPA Omnibus Declaratory Ruling and Order, July 2015, paragraphs 138 and 139, communications from banking institutions which are exempt "...are all intended to address exigent circumstances in which a quick, timely communication with a consumer could prevent considerable consumer harms from occurring or, in the case of the remediation calls, could help quickly mitigate the extent of harm that will occur." Pursuant to Paragraph 139, (3) and (7) "In light of these considerations, we adopt the following conditions for each exempted call (voice call or text message) made by a financial institution: 3) voice calls and text messages are strictly limited to purposes discussed in paras. 129-137 above and must not include any telemarketing, cross-marketing, solicitation, debt collection, or advertising content; 7) a financial institution must honor opt-out requests immediately."   Defendants violated various provisions of the TCPA, including but not limited to 47 USC $227(bXAXiii). *  DEMANp ron TBI4I{ BY JU.RY  Plaintiffs hereby respectfully request a trial by jury for all clarms and issues in its Complaint to which it is or may be entitled to a jury tial. PRAYER rqR REL{Sr WHEREFORE, Plaintitrs demands judgment &omthe Defendaots as follows: A.  For actual damages provided and pursuant to 15 USC $16ek (a) (l); B.  For statutory damages provided aild pursuant to 15 USC $16e2(2XA); C.  For statutory darnages provided and pursuant to 15 usc$16e2k(2xB); D.  For attorneys' fees and costs provided and pursuant to I5USC$1692(a)(3); E.  A declaration that the Defendants' practices violated the