A. I have twice notified IC System ( " ICS '' ) in writing that I dispute the validity of the entire debt which ICS is attempting to collect from me. Both notifications were delivered to ICS within the 30-day window provided under XXXX XXXX XXXX ( a ). 

B. Accordingly, a debt collector ( " DC '' ) must cease collection of the debt, or any disputed portion thereof, until the DC obtains verification of the debt or any copy of a judgment, or the name and address of the original creditor, and a copy of such verification or judgment, or name and address of the original creditor, is mailed to the consumer by the DC. XXXX XXXX. XXXX ( b ). 

C. ICS has not ceased calling me after I informed them in writing that I dispute the entire debt. ICS has further failed to provide me with any verification or evidence of a debt owed by me, as required under XXXX XXXX XXXX ( b ). 

D. In XXXX letters to ICS, I provided indisputable evidence that this debt is invalid. Such evidence included a statement from the " creditor '' for whom XXXX claims to be collecting a debt, showing that my account does not have a negative balance ; to the contrary, " creditor '' owed me a credit. I also attached evidence that the " creditor '' credited my account on XXXX XXXX, 2016. 

E. In XXXX letters, I notified ICS that I refuse to pay ICS anything, as no such debt exists, and that ICS that it is required to cease further communication with me. Accordingly, ICS is required to do so pursuant to XXXX XXXX XXXX ( c ). 

F. By law, after such notification, ICS may only contact me for the following reasons : ( 1 ) to advise the me that ICS 's further efforts are being terminated ; ( 2 ) to notify the me that ICS may invoke specified remedies which are ordinarily invoked by such XXXX ; or ( 3 ) to notify the me that the ICS intends to invoke a specified remedy. 

G. ICS has continuously failed its statutory duties, as it has proceeded to call me 3-5 times/day for the past 3 weeks following receipt of my first letter. ICS has left no message, nor have they mailed me any notification, stating that their efforts to communicate me are for XXXX of the XXXX lawful purposes allowed under XXXX XXXX XXXX ( c ). For this reason, I presume that the calls are unlawful under XXXX XXXX. XXXX ( c ). 

H. As these calls do not fall within the XXXX categories enumerated above, these calls may be considered an attempt to harass, oppress, or abuse any person in connection with the collection of a debt, as defined under XXXX XXXX XXXX. Federal law prohibits a DC from causing a telephone to ring repeatedly or continuously with intent to annoy, abuse, or harass any person at the called number. XXXX XXXX. XXXX ( XXXX ). Federal law also prohibits a DC placement of telephone calls without meaningful disclosure of the caller 's identity. XXXX XXXX. XXXX ( XXXX ). 

I. In its letter to me regarding the debt, ICS threatened to report my information to credit reporting agencies ( " CRA '' ). Before reporting my information to a CRA, ICS must conduct a reasonable investigation of a direct dispute. XXXX XXXX XXXX ( a ). After receiving a dispute notice from me, ICS must conduct a reasonable investigation with respect to the disputed information ; review all relevant information provided by the consumer with the dispute notice ; complete its investigation of the dispute and report the results of the investigation to me before the expiration of the period. XXXX XXXX XXXX ( e ). In addition, if the completeness or accuracy of any information furnished by any person to any CRA is disputed to such person by a consumer, the person may not furnish the information to any CRA without notice that such information is disputed by the consumer. XXXX XXXX. 

J. In light of the evidence presented by me, I have reason to believe that ICS still reported my information to CRAs, and has yet to correct such misinformation. 
