11. 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.   12. Some time prior to March 17, 2021, an obligation was allegedly incurred to JPMorgan  Chase Bank N.A. (“CREDITOR”).   13. The JPMorgan Chase Bank N.A. obligation arose out of a consumer transaction in which  money, property, insurance or services, which are the subject of the transaction, are  primarily for personal or family purposes.   14. The alleged JPMorgan Chase Bank N.A. obligation is a "debt" as defined by 15 U.S.C.§  1692a(5).   15. JPMorgan Chase Bank N.A. is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   16. At some point, JPMorgan Chase Bank N.A. or a purchaser, assignee, or subsequent creditor  sold the debt to the Defendant.   17. Defendant then decided to contact Plaintiff about the debt via written correspondence in an  attempt to collect the alleged debt.    18.  However, rather than preparing and mailing a collection letter on its own, Defendant sent  information regarding Plaintiff and the Debt to a commercial mail house (“mail house”).    20. Defendant disclosed to the mail house:   a. Plaintiff status as a debtor;   b. the fact that Plaintiff allegedly owed $6,877.75 to JPMorgan Chase Bank N.A.;  and  c. other highly personal pieces of information.    21. The mail house then populated some or all of this information into a pre-written template,  printed, and prepared the letter for mailing to Plaintiff’s residence in New York.    22. The FDCPA defines “communication” at 15 U.S.C. § 1692a(3) as “the conveying of  information regarding a debt directly or indirectly to any person through any medium.”   23. The sending of an electronic file containing information about Plaintiff’s purported debt to  a mail house is therefore a communication.   24. Defendant’s communication to the mail house was in connection with the collection of a  Debt since it involved disclosure of the Debt to a third-party with the objective being  communication with, and motivation of, the consumer to pay the alleged Debt.   25. Plaintiff never consented to having her personal and confidential information, concerning  the Debt or otherwise, shared with anyone else.   26. In limiting disclosures to third parties, the FDCPA states, at 15 U.S.C. § 1692c(b):  “Except as provided in section 1692b of this title, without the prior consent  of the consumer given directly to the debt collector, or the express  permission of a court of competent jurisdiction, or as reasonably necessary  to effectuate a post judgment judicial remedy, a debt collector may not  communicate, in connection with the collection of any debt, with any person  other than the consumer, his attorney, a consumer reporting agency if  otherwise permitted by law, the creditor, the attorney of the creditor, or the  attorney of the debt collector.” (emphasis added).   28. Due to Defendant’s communication to this mail house, information about Plaintiff -  including her name, the amount allegedly owed, and Plaintiff’s home address - are all  within the possession of an unauthorized third-party.   29. If a debt collector “conveys information regarding the debt to a third party - informs the  third party that the debt exists or provides information about the details of the debt - then  the debtor may well be harmed by the spread of this information.” Brown v. Van Ru Credit  Corp., 804 F.3d 740, 743 (6th Cir. 2015).   30. Defendant unlawfully communicates with the unauthorized third-party mail house solely  for the purpose of streamlining its generation of profits without regard to the propriety and  privacy of the information which it discloses to such third-party.   31. In its reckless pursuit of a business advantage, Defendant disregarded the known, negative  effect that disclosing sensitive information to an unauthorized third-party has on  consumers.   32. As a result of the Defendant’s violations of the FDCPA, the Plaintiff was harmed.  Plaintiff  was harmed by being subjected to abusive collection practices, from which she had a  substantive right to be free, by having her privacy invaded, and by having her private and  protected information shared and disseminated with unauthorized parties.  33. Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ. P. 23(a)  and 23(b)(3):   35. 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 debts.   36. Excluded from the Plaintiff Class are the Defendant and all officers, members, partners,  managers, directors, and employees of the Defendant and their respective immediate  families, and legal counsel for all parties to this action and all members of their immediate  families.   37. 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 Defendant’s practice, of sharing debtor’s personal and protected information  with its mail house, violates 15 U.S.C. §§ 1692c and 1692f.   38. The Plaintiff’s claims are typical of the class members, as all are based upon the same facts  and legal theories.   39. 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 Plaintiff’s  attorneys have any interests, which might cause them not to vigorously pursue this action.   42. 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).  43. 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.   44. 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. § 1692c.    45. Pursuant to Section 15 U.S.C. §1692c of the FDCPA:  “Except as provided in section 1692b of this title, without the prior consent of the  consumer given directly to the debt collector, or the express permission of a court  of competent jurisdiction, or as reasonably necessary to effectuate a post judgment  judicial remedy, a debt collector may not communicate, in connection with the  collection of any debt, with any person other than the consumer, his attorney, a  consumer reporting agency if otherwise permitted by law, the creditor, the attorney  of the creditor, or the attorney of the debt collector.” (emphasis added).   46. The Defendant violated said provision by conveying Plaintiff’s information to its mail  house in connection with the collection of Plaintiff’s debt, in violation of 15 U.S.C. §1692c.   47. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant’s conduct  violated Section 1692c et seq. of the FDCPA, statutory damages, costs and attorneys’ fees.   48. 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.   49. 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.   50. Defendant violated 15 U.S.C. § 1692f by using unfair means in connection with the  collection a debt, to wit, knowingly disclosing sensitive information about Plaintiff’s debt  to third parties not expressly authorized under the FDCPA.   51. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's 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. §1692c et seq.  