 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 Texas;  b.  to whom Defendant ERC 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.    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.    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.    This action has been brought, and may properly be maintained, as a class action  pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure because there is a  well-defined community interest in the litigation:  a. Numerosity: The Plaintiff is informed and believes, and on that basis alleges,  that the Plaintiff Class defined above is so numerous that joinder of all members  would be impractical.  b. Common Questions Predominate: Common questions of law and fact exist as  to all members of the Plaintiff Class and those questions predominance over any  questions or 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 USC §l692e.  c. Typicality: The Plaintiff’s claims are typical of the claims of the class members.  The Plaintiffs and all members of the Plaintiff Class have claims arising out of  the Defendants' common uniform course of conduct complained of herein.  d. Adequacy: The Plaintiff will fairly and adequately protect the interests of the  class members insofar as Plaintiff have no interests that are adverse to the absent  class members. The Plaintiff is committed to vigorously litigating this matter.  Plaintiff has also retained counsel experienced in handling consumer lawsuits,  complex legal issues, and class actions. Neither the Plaintiff nor her counsel have  any interests which might cause them not to vigorously pursue the instant class  action lawsuit.  e. Superiority: A class action is superior to the other available means for the fair  and efficient adjudication of this controversy because individual joinder of all  members would be impracticable. Class action treatment will permit a large  number of similarly situated persons to prosecute their common claims in a single  forum efficiently and without unnecessary duplication of effort and expense that  individual actions would engender.    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.    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 5, 2021, an obligation was allegedly incurred to Sprint,  subsidiary of T-Mobile by the Plaintiff.    The Sprint, subsidiary of T-Mobile 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 Sprint, subsidiary of T-Mobile obligation is a “debt” as defined by 15  U.S.C. §1692a(5).    Sprint, subsidiary of T-Mobile is a “creditor” as defined by 15 U.S.C. §1692a(4).    Defendant ERC, a debt collector, was contracted by Sprint, subsidiary of T-Mobile  to collect the alleged debt which originated with Sprint, subsidiary of T-Mobile.    Defendants collect and attempt to collect debts incurred or alleged to have been  incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and internet.  Violation I – March 5, 2021 Collection Letter    On or about March 5, 2021, Defendant ERC sent Plaintiff a collection letter (the  “Letter”) regarding the alleged debt currently owed to T-Mobile See Exhibit A.    The letter states an original balance of $1,213.49    The collection letter states: “Our records indicate that your balance with Sprint, now  part of the T-Mobile Network, remains unpaid; therefore, your account has been placed with  ERC for collection efforts.  We are authorized to settle your account for less than the full original  balance in the amount of $667.42.  Upon completion of the settlement agreement, all future  collection efforts will cease, and the residual balance will remain with Sprint.”    The letter is deceptive because it implies that in exchange for payment of less than  the full balance the consumer will achieve some form of settlement, when in actuality it is  unclear what form of settlement the letter is offering.    This is especially deceptive because the letter actually uses the term “settlement  agreement.”    The letter states that Sprint will 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  part of the balance.    The letter deceives and misleads the consumer by implying that paying “the  settlement” amount would achieve results akin to a settlement offer, when in reality the  Defendant’s offer contains no significant benefits and is unclear to what the benefits of the  “settlement agreement” would actually be.    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.    Defendant violated said section by:   a. Making a false and misleading representation in violation of but not limited to  §1692e (10).    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.  