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 Class consists of:   a.  all individuals with addresses in the State of New Jersey;  b.  to whom Defendant sent an initial collection letter;  c.  attempting to collect a consumer debt;  d.  providing multiple addresses;  e.  without identifying the correct address to which to send a dispute; and  f.  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 (21) days after the filing of this action.    The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf they attempt to collect and/or have  purchased debts.    Excluded from the Plaintiff Class is the Defendant and all officers, members, partners,  managers, directors and employees of the Defendant and its respective immediate families, and legal  counsel for all parties to this action, and all members of their immediate families.     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 his attorneys  have any interests, which might cause them not to vigorously pursue this action.    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 the above allegations as if set forth herein.   The name of the creditor to whom the debt is owed;    The obligation arose out of a transaction involving a consumer debt to BMW  Financial Services in which money, property, insurance or services, which are the subject of the  transaction, were incurred solely for personal purposes, specifically a personal automobile.    The alleged BMW Financial Services obligation is a "debt" as defined by 15 U.S.C.§  1692a (5).    BMW Financial Services is a "creditor" as defined by 15 U.S.C. § 1692a (4).    Upon information and belief, BMW Financial Services contracted with the  Defendant to collect the alleged debt. Therefore, Defendant is a “debt collector” as defined by 15  U.S.C. § 1692a (6).    Defendant collects and attempts 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 – October 12, 2020 Collection Letter    On or about October 12, 2020, Defendant sent the Plaintiff an initial collection letter  regarding the alleged debt owed to BMW Financial Services.  (See “Letter” attached as Exhibit A).    The letter ostensibly provides the notices as required by 15 U.S.C. § 1692g regarding  disputing the debt.    However, there are three addresses listed for Defendant in two different states:   a. 9 Wills Way, Piscataway, NJ 08854  b. PO Box 1121, Charlotte, NC 28201  c. PO Box 55, 3 Skiles Ave, Piscataway, NJ 08855   A statement that unless the consumer, within thirty days after  receipt of the notice, disputes the validity of the debt, or any  portion thereof, the debt will be assumed to be valid by the debt- collector;    Plaintiff was therefore confused as to how to properly dispute the debt and exercise  his rights under § 1692g.    Upon information and belief, disputes sent to one or more of these addresses will not  be honored by Defendant.    Listing these incorrect addresses(es) misled Plaintiff into believing a proper dispute  cannot be sent there.    Plaintiff was therefore unable to straightforwardly dispute the debt resulting in  wasted time.    Plaintiff was therefore unable to evaluate his options of how to handle this debt.    Because of this, Plaintiff expended time, money, and effort in determining the proper  course of action.    As Plaintiff did not understand how to dispute the debt, Plaintiff paid off the balance  of the debt out of fear of further accrual of interest and fees and damage to his credit score. However,  Plaintiff wanted to dispute the debt and would have done so if the dispute process was  comprehendible.      These violations by Defendant were knowing, willful, negligent and/or intentional,  and Defendant did not maintain procedures reasonably adapted to avoid any such violations.    Defendant’s collection efforts with respect to this alleged debt from Plaintiff caused  Plaintiff to suffer concrete and particularized harm, inter alia, because the FDCPA provides Plaintiff  with the legally protected right not to be misled or treated unfairly with respect to any action  regarding the collection of any consumer debt.   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 actions created an appreciable risk to Plaintiff of being unable to  properly respond or handle Defendant’s debt collection.    Plaintiff was confused and misled to his detriment by the statements in the dunning  letter, and relied on the contents of the letter to his detriment.    Plaintiff would have pursued a different course of action were it not for Defendant’s  statutory violations.    As a result of Defendant’s deceptive, misleading and false debt collection practices,  Plaintiff has been damaged.   Plaintiff repeats the above allegations as if set forth 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 deceptively and/or misleadingly providing  multiple addresses and not identifying which one should be used to dispute the debt, in violation  of § 1692e (10).    Plaintiff repeats the above allegations as if set forth herein.   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.    In the alternative, 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. § 1692f.    Pursuant to 15 U.S.C. § 1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.    Defendant violated this section by unfairly providing multiple addresses and not  identifying which one to use for disputing a debt.    By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant's  conduct violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.   Plaintiff repeats the above allegations as if set forth 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.    By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant's  conduct violated Section 1692g et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692f et seq.   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.  