 Plaintiff brings this claim on behalf of the following class, 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 New Jersey;  b.  to whom Defendant Convergent sent a collection letter attempting to collect a  consumer debt;  c. containing deceptively worded settlement offers;   d. 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.    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.     There are questions of law and fact common to the Plaintiff Class, which common  issues predominate over any issues involving only individual class members. The principal issue  is whether the Defendants' written communications to consumers, in the forms attached as  Exhibit A, violate 15 U.S.C. §§ l692e.    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.    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.    Some time prior to March 20, 2021, an obligation was allegedly incurred to T- Mobile, USA by the Plaintiff.    The T-Mobile, USA obligation arose out of transactions in which money, property,  insurance or services which are the subject of the transactions were primarily for personal,  family or household purposes, specifically telecommunication services.    The alleged T-Mobile, USA obligation is a “debt” as defined by 15 U.S.C.  §1692a(5).    T-Mobile, USA is a “creditor” as defined by 15 U.S.C. §1692a(4).    Defendant Convergent, a debt collector, was contracted by T-Mobile, USA to collect  the alleged debt which originated with T-Mobile, USA    On or about March 20, 2021, Defendant Convergent sent Plaintiff a collection letter  (the “Letter”) regarding the alleged debt currently owed to Defendant T-Mobile, USA See  Exhibit A.    The letter states a balance of $602.65.    The collection letter further states: “We have been authorized to accept payment of  50% of the total amount owed, which is $301.33, in exchange for which T-Mobile, USA will  recall your account and cease all collection activity. If you are interested in taking advantage of  this offer, call our office within 60 days of the date of this letter.  Please note that this is not an  offer to accept 50% of your debt as payment in full, but an offer for T-Mobile, USA to remove  your account from further collection efforts.  We are not obligated to renew this offer.”    The letter is deceptive because it implies that in exchange of 50% of the balance the  consumer will achieve some form of settlement, when in actuality it is unclear what form of  settlement the letter is offering.    The letter states that T-Mobile, USA will recall the account and cease all collection  activity but does not clarify what will occur with the rest of the balance and whether the rest of  the balance would be collected by another collection company in the future.    Nor does the letter clearly state that the account will be reinstated upon payment of  50% of the balance.    In addition, the letter contains a misleading heading stating “Reduced Balance  Opportunity.”    The letter states that Plaintiff can pay half of her balance, seemingly without reducing  the balance beyond the amount that the Plaintiff actually paid.    Paying half of the balance with a result of the other half of the balance still remaining  cannot be described as a “Reduced Balance Opportunity,” as the option of paying half of the  balance is always available as a means of reducing a balance.    Moreover, the letter implies that this offer is expiring which is deceptive because the  option of paying half of a balance never actually expires.    As a result of Defendant’s deceptive, misleading and false 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.    Defendant’s 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.    By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e, et seq. of the FDCPA and is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e et seq.  