 Plaintiffs bring 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  Defendant and those companies and entities on whose behalf they attempt to collect and/or have  purchased debts.    Excluded from the Plaintiff Classes 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 Classes, which common  issues predominate over any issues involving only individual class members. The principal issue  is whether the Defendant’s written communications to consumers, in the form attached as  Exhibit A, violate 15 U.S.C. §§ l692e and 1692f.    The Plaintiffs’ claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiffs will fairly and adequately protect the interests of the  Plaintiff Classes defined in this complaint. The Plaintiffs have retained counsel with experience  in handling consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiffs  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, Plaintiffs 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 November 3, 2020, an obligation was allegedly incurred to  Synchrony Bank.    The Synchrony Bank obligation arose out of a transaction in which money, property,  insurance or services, which are the subject of the transaction, are primarily for personal, family  or household purposes, specifically a Wal-Mart credit card.    The alleged Synchrony Bank obligation is a “debt” as defined by 15 U.S.C.  §1692a(5).    Defendant PRA, a debt collector and the subsequent owner of the alleged  Synchrony Bank, is collecting the alleged debt.    On or about November 3, 2020, Defendant PRA sent the Plaintiff a notice (the  “Letter”) regarding the alleged debt owed to Synchrony Bank. See Attached hereto as Exhibit  A.     The Letter states a balance of $ 5,069.20.    The Letter offers two options regarding the balance: Pay the full amount in either  one, six or twelve payments or choose a “savings plan” that allows the consumer to pay the  balance for a discounted amount in one, twelve or eighteen consecutive months.     Defendant’s offer is illogical. Why choose to pay the full balance when there is an  offer to pay less than the full balance?    The only answer would be that paying in full would receive some form of added  benefit.     Defendant’s letter does not make any mention of any benefit or incentive to pay the  full balance rather than the discounted amount.    Therefore, the consumer is left confused and misled which option to choose; on the  one hand the discounted amount saves him money but on the other hand, the full payment option  must have some benefit or else it would not even be a consideration.     Yet Defendant’s letter mentions no benefit whatsoever of paying the full balance,  making the letter illogical and leaving the consumer wondering if there is a “catch” or if this is  a real offer.      Defendant’s letter it is open to more than one reasonable interpretation, at least one  of which is inaccurate    As a result of Defendant’s deceptive, misleading and unfair 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.    Defendants’ 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 §1692e :   a. As the Letter it is open to more than one reasonable interpretation, at least one of  which is inaccurate.  b. By making a false and misleading representation in violation of §1692e(10).    By reason thereof, Defendants are liable to Plaintiff for judgment that Defendants’  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.   Defendants’ debt collection efforts attempted and/or directed towards 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.    Defendants violated this section by omitting material information that gave Plaintiff  a false understanding of the offers in the Letter.    By reason thereof, Defendants are liable to Plaintiff for judgment that Defendants’  conduct violated Section 1692f 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. §1692e  et seq.  