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 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.    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).  The name of the creditor to whom the debt is owed;    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 April 5, 2019, an obligation was allegedly incurred to Discover  Bank (hereinafter, “Discover”).    The Discover obligation arose out of transactions in which money, property,  insurance or services were the subject of the transactions, specifically extending a revolving  line of credit on a personal credit card.    The alleged Discover obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).    Discover is a "creditor" as defined by 15 U.S.C.§ 1692a(4).    Defendant Van Ru, a debt collector, was contracted by Discover to collect the alleged  debt.    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    On or about April 5, 2019 Defendant sent Plaintiff an initial contact notice (the  “Letter”) regarding the alleged debt owed.     Shortly after receiving the Letter, Plaintiff’s husband under instruction from the  Plaintiff and as per the Letter stated, placed a telephone call to Defendant attempting to dispute  the Discover account.   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;    When asked by the Defendant the reason for the call, Plaintiff advised it was to  dispute the Discover account referenced in the Letter.      Immediately thereafter Defendant requested a reason for the dispute, to which  Plaintiff’s husband stated the he was just disputing the debt as per the instructions in the Letter.    Plaintiff then sought to affirm Defendant’s disclosure regarding the dispute process,  specifically that the dispute must be in writing or the account would not be disputed.  Defendant  advised that he was correct, that the dispute must be in writing.     To demand both a dispute to be in writing and/or contain a specific reason is  completely contradictory to both the specific consumer rights stated in the initial collection letter  as well as relevant case law in this Jurisdiction.    Furthermore, it is a clear attempt to circumvent the verification process and pause  collection efforts for any period of time.    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.    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 stating that they would only accept  disputes in writing.     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. §1692e  et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692g  et seq.  