 In the last line of the Collection Letter, in much smaller print, Defendant states, "The law  limits how long a debt can appear on your credit report. Due to the age of this debt, we will not  report payment or non-payment of it to a credit bureau."    Nor did the letter inform Plaintiff that a partial payment on the debt would restart the  running of the statute of limitations. In fact, had Plaintiff chosen a payment plan option, and  advised Defendant of this in writing, the partial payment would revive the statute of limitations  rendering the Plaintiff worse off than if she had rejected the offer.    It is the position of the Federal Trade Commission, the Consumer Financial Protection  Bureau, the Federal Deposit Insurance Corporation, the Federal Reserve Board, and the Office of  the Comptroller of the Currency that when "collecting on a time barred debt a debt collector  [Defendant] must inform the consumer [Plaintiff] that (1) the collector cannot sue to collect the  debt and (2) providing a partial payment would revive the collector's [Defendant's] ability to sue  to collect the balance." McMahon v. LVNV Funding, LLC, 774 F.3d 1010, 1015 (7th Cir. 2014); see  White v. First Step Grp. LLC, 2017 LEXIS 153569 (E.D. Cal. Sept. 19, 2017).    The Defendant engaged in misleading, deceptive, and unfair debt collection practices in  violation of the FDCP A by its Collection Letter to the Plaintiff.   Plaintiff brings this as a class action pursuant to Fed. R. Civ. P. 23.    Plaintiff seeks certification of the following classes, initially defined as follows:  Class: All consumers with a Pennsylvania address that have received collection letters similar  to Exhibit A from Defendant concerning debts for GE Capital Retail Bank used primarily  for personal, household, or family purposes within one year prior to the filing of this  complaint.    Upon information and belief, Defendant has sent collections letters in attempt to collect a  debt to hundreds if not thousands of consumers Pennsylvania, each of which violates the FDCP A.  The members of the Class, therefore, are believed to be so numerous thatjoinder of all members is  impracticable.    The letters sent by Defendant, and received by the Class, are to be evaluated by the objective  standard of the hypothetical "least sophisticated consumer."    The exact number and identities of the Class members are unknown at this time and can  only be ascertained through discovery. Identification of the Class members is a matter capable of  ministerial determination from Defendant's records.  Common Questions of Law and Fact    There are questions of law and fact common to the class that predominates over any  questions affecting only individual Class members. These common questions of law and fact  include, without limitation: (i) whether Defendant violated various provisions of the FDCP A; (ii)  whether the Plaintiff and the Class have been injured by the conduct of Defendant; (iii) whether  the Plaintiff and the Class have sustained damages and are entitled to restitution as a result of  Defendants wrongdoing and, if so, what is the proper measure and appropriate statutory formula to  be applied in determining such damages and restitution; and (iv) whether the Plaintiff and the Class  are entitled to declaratory and/or injunctive relief.  Typicality    Plaintiff will fairly and adequately represent the Class members' interests, in that the  Plaintiffs counsel is experienced and, further, anticipates no impediments in the pursuit and  maintenance of the class action as sought herein.    Neither the Plaintiff nor his counsel have any interests, which might cause them not to  vigorously pursue the instant class action lawsuit.  Proceeding Via Class Action is Superior and Advisable    A class action is superior to other methods for the fair and efficient adjudication of the  claims herein asserted, this being specifically envisioned by Congress as a principal means of  enforcing the FDCPA, as codified by 15 U.S.C.§ 1692(k).    The members of the Class are generally unsophisticated individuals, whose rights will not  be vindicated in the absence of a class action.    Prosecution of separate actions by individual members of the Class would create the risk of  inconsistent or varying adjudications resulting in the establishment of inconsistent or varying  standards for the parties.    Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure is also  appropriate in that the questions of law and fact common to members of the Plaintiffs Class  predominate over any questions affecting an individual member, and a class action is superior to  other available methods for the fair and efficient adjudication of the controversy.    A class action will permit a large number of similarly situated persons to prosecute their  common claims in a single forum simultaneously, efficiently, and without the duplication of effort  and expense that numerous individual actions would engender. Class treatment also will permit the  adjudication of relatively small claims by many Class members who could not otherwise afford to  seek legal redress for the wrongs complained of herein.    Absent a class action, the Class members will continue to suffer losses borne from  Defendant's breaches of Class members' statutorily protected rights as well as monetary damages,  thus allowing and enabling: (a) Defendant's conduct to proceed and; (b) Defendant to further enjoy  the benefit of its ill-gotten gains.    Defendant has acted, and will act, on grounds generally applicable to the entire Class,  thereby making appropriate a final injunctive relief or corresponding declaratory relief with respect  to the Class as a whole.   Plaintiff repeats the allegations contained in the above paragraphs and incorporates them as  if specifically set forth at length herein.    Defendant's Collection Letter is false, deceptive, and misleading, and violates the below  provisions of the FDCP A.    On a date better known by Defendant, Plaintiff incurred a debt from the use of a credit  card to purchase goods used for personal, family, and household purposes.    On a date better known by Defendant, Defendant began attempting to collect on said debt  allegedly owed by the Plaintiff.    On or about January 11, 201 7, Defendant sent Plaintiff the letter attached as Exhibit A,  presenting the "current balance" as $470.52, for a personal debt originating with GE Capital  Retail Bank and Old Navy.    The Collection Letter offered three available payment options. Option one (1) was for a  payment due by February 10, 2017 for 40% off. Option two (2) was for 20% off with payments  over 3 months. Option three (3) was for "monthly payments as low as $50 per month." See  Exhibit A. Therefore, Options 2 and 3 clearly offered payments over time.   The Class   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692 et seq.  