 Upon information and belief, Exhibit A is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.     Exhibit A was the first letter GCS sent to Plaintiff regarding this alleged debt.    Exhibit A includes the FDCPA debt validation notice. 15 U.S.C. § 1692g(a).    GCS’ letter as a whole is confusing and misleading to the unsophisticated  consumer.    Exhibit A states:  New Balance: $972.44  Minimum Payment Due: $972.44    Exhibit A, thus, informs the unsophisticated consumer that GCS is "here to work  with [her] to find a mutually agreeable solution," while at the same time, stating that the  minimum payment she may make is the entirety of the balance.    Exhibit A is confusing to the unsophisticated consumer because there cannot be  other opportunities available if the minimum payment is in the amount of the entire balance.    Exhibit A also states:  * As of the date of this letter, you owe $972.44. Because of interest, late charges, and other charges  that may vary from day to day, the amount owed on the day you pay may be greater. Hence, if you  pay the amount shown above, an adjustment may be necessary after we receive your payment, in  which event we will inform you.    Exhibit A, thus, informs the unsophisticated consumer that additional charges  may be added after GCS receives payment of "the amount shown above."    Exhibit A is confusing to the unsophisticated consumer. Because the "new  balance" is equal to the "minimum payment due," it is unclear whether the minimum payment  due is also subject to "interest, late charges, and other charges that may vary from day to day," in  which case the unsophisticated consumer would not know whether the minimum payment at the  time was $972.44 or some other amount.    The "New Balance" and "Minimum Payment Due" amounts, read alongside the  note that the "amount owed on the day you pay may be greater," render Exhibit A confusing to  the unsophisticated consumer, who would not be able to determine, or would be confused as to,  the actual minimum payment required.    Moreover, the alleged debt here is an unsecured credit card account and, upon  information and belief, GCS and DNSB would accept any payment of any amount at any time.    Plaintiff was confused by Exhibit A.    Plaintiff had to spend time and money investigating Exhibit A, and the  consequences of any potential responses to Exhibit A.    Plaintiff had to take time to obtain and meet with counsel, including traveling to  counsel’s office by car and its related expenses, including but not limited to the cost of gasoline  and mileage, to advise Plaintiff on the consequences of Exhibit A.  The FDCPA    15 U.S.C. § 1692e generally prohibits “any false, deceptive, or misleading  representation or means in connection with the collection of any debt.”    15 U.S.C. § 1692e(2)(a) specifically prohibits the “false representation of the  character, amount, or legal status” of an alleged debt.    15 U.S.C. § 1692e(10) specifically prohibits the “use of any false representation  or deceptive means to collect or attempt to collect any debt.”    15 U.S.C. § 1692f generally prohibits “unfair or unconscionable means to collect  or attempt to collect any debt.”    15 U.S.C. § 1692g(b) states, in part:  (b) Disputed debts   …  Any collection activities and communication during the 30-day period may not  overshadow or be inconsistent with the disclosure of the consumer’s right to  dispute the debt or request the name and address of the original creditor.    Moreover, Congress has explicitly described the FDCPA as regulating “abusive  practices” in debt collection. 15 U.S.C. §§ 1692(a) – 1692(e). Any person who receives a debt  collection letter containing a violation of the FDCPA is a victim of abusive practices. See 15  U.S.C. §§ 1692(e) (“It is the purpose of this subchapter to eliminate abusive debt collection  practices by debt collectors, to insure that those debt collectors who refrain from using abusive  debt collection practices are not competitively disadvantaged, and to promote consistent State  action to protect consumers against debt collection abuses”). For this reason, and to encourage  consumers to bring FDCPA actions, Congress authorized an award of statutory damages for  violations. 15 U.S.C. § 1692k(a).   Plaintiff incorporates by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.    The unsophisticated consumer would be confused as to whether GCS was  authorized to approve a payment schedule that called for payments less than the "minimum  payment due."    The unsophisticated consumer would also be confused as to whether the  minimum payment due was subject to day-to-day increases as interest, late fees, and/or other  charges accrued.    GCS’ conduct violates 15 U.S.C. §§ 1692e, 1692e(2)(a), 1692e(10), 1692(f) and  1692g(a)(1).   Plaintiff brings this action on behalf of a Class consisting of (a) all natural persons  in the State of Wisconsin, (b) who were sent an initial collection letter in the form represented by  Exhibit A to the complaint in this action, (c) seeking to collect a debt, incurred for personal,  family or household purposes (d) between July 28, 2016 and July 28, 2017, inclusive, (e) that  was not returned by the postal service.    The Class is so numerous that joinder is impracticable.  Upon information and  belief, there are more than 50 members of the Class.    There are questions of law and fact common to the members of the class, which  common questions predominate over any questions that affect only individual class members.   The predominant common question is whether Exhibit A violates the FDCPA.    Plaintiff’s claims are typical of the claims of the Class members.  All are based on  the same factual and legal theories.    A class action is superior to other alternative methods of adjudicating this dispute.    Individual cases are not economically feasible.   On or about June 25, 2017 mailed a debt collection letter to Plaintiff regarding an  alleged debt owed to “Department Stores National Bank" (“DSNB”). A copy of this letter is  attached to this Complaint as Exhibit A.    The alleged debt referenced in Exhibit A was a credit card account, and the  alleged debt was incurred for personal, family or household purposes, including purchases of  clothing and other personal goods at Macy's.  