The amount of the debt;    Plaintiff brings this claim on behalf of the following case, pursuant to  Fed. R. Civ. P. 23(a) and 23(b)(3).    The identities of all class members are readily ascertainable from the  records of Defendants and those companies and entities on whose behalf they  attempt to collect and/or have purchased debts.    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 and 1692g.    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 Plaintiff 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.    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.   The name of the creditor to whom the debt is owed;    Some time prior to October 25, 2019, an obligation was allegedly  incurred to Salal Credit Union by Plaintiff.    The Salal Credit Union 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.    The alleged Salal Credit Union obligation is a “debt” as defined by 15  U.S.C. §1692a(5).    Salal Credit Union is a “creditor” as defined by 15 U.S.C. §1692a(4).    Defendant FAI was contracted by Salal Credit Union  to collect the  alleged debt.    On or about October 25, 2019, Defendant FAI sent Plaintiff an initial  collection letter (the “Letter”) regarding the alleged debt currently owed. See  Exhibit A.    The FDCPA further provides that ''if the consumer notifies the debt  collector in writing within the thirty day period . . . that the debt, or any portion  thereof, is disputed . . . the debt collector shall cease collection . . . until the debt  collector obtains verification of the debt . . . and a copy of such verification is  mailed to the consumer by the debt collector.'' 15 U.S.C. § 1692g(b).    Although a collection letter may track the statutory language, ''the  collector nevertheless violates the Act if it conveys that information in a  confusing or contradictory fashion so as to cloud the required message with  uncertainty.'' Russell v. EQUIFAX A.R.S., 74 F.3d 30, 35 (2d Cir. 1996) (''It is  not enough for a debt collection agency to simply include the proper debt  validation notice in a mailing to a consumer-- Congress intended that such  notice be clearly conveyed.''). Put differently, a notice containing ''language that  'overshadows or contradicts' other language informing a consumer of her  rights . . . violates the Act.'' Russell, 74 F.3d at 34.    This language completely overshadows the “G-Notice” by scaring  Plaintiff into making payment immediately to avoid negative credit reporting  instead of exercising her statutory right to dispute the debt as provided by the   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.   A statement that the consumer notifies the debt collector in  writing within thirty-day period that the debt, or any portion  thereof, is disputed, the debt collector will obtain  verification of the debt or a copy of a judgment against the  consumer and a copy of such verification or judgment will  be mailed to the consumer by the debt collector; and    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.    Defendant violated said section by:   a. Making a false and misleading representation in violation of  §1692e(10).    By reason thereof, Defendant is liable to Plaintiff for judgment that  Defendant's conduct violated Section 1692e et seq. of the FDCPA, actual  damages, statutory damages, costs and attorneys’ fees.    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. § 1692g.     Pursuant to 15 USC §1692g, a debt collector:  Within five days after the initial communication with a consumer in  connection with the collection of any debt, a debt collector shall, unless the  following information is contained in the initial communication or the  consumer has paid the debt, send the consumer a written notice containing –    The Defendant violated 15 U.S.C. §1692g, by threatening negative  credit reporting, which overshadows the ''g-notice'' language and coerces the  consumer not to exert its rights under the FDCPA.     By reason thereof, Defendant is liable to Plaintiff for judgment that  Defendant's conduct violated Section 1692g et seq. of the FDCPA, actual  damages, statutory damages, costs and attorneys’ fees.  A statement that, upon the consumer’s written request within  the thirty-day period, the debt collector will provide the  consumer with the name and address of the original creditor,  if different from the current creditor.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES  ACT 15 U.S.C. §1692g et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15  U.S.C. §1692e et seq.  