15.  Plaintiff had residential service with Verizon.     16.  Plaintiff advised Verizon that she was moving and ordered that her service be  transferred by Verizon to her new address.    17.  However, Verizon failed to transfer the services and instead kept the services active  at the old address after Plaintiff had moved, as well as at her new address.     18.  Thereafter, Verizon billed Plaintiff $382.25 for services provided to the old address  (“the alleged Debt”).     19.  For the foregoing reasons, Plaintiff did not owe Verizon $382.25 (“the Claimed  Amount”).   20.  Nevertheless, at an exact time known only to Defendant, the alleged Debt was  assigned or otherwise transferred by Verizon to Defendant for collection.    21.  In its efforts to collect the alleged Debt, Defendant decided to contact Plaintiff by  written correspondence.   22.  Upon information and belief, rather than preparing and mailing such written  correspondence to Plaintiff on its own, Defendant decided to utilize a third-party in Oaks,  Pennsylvania to perform such activities on its behalf.   23.  Upon information and belief, the third party is RevSpring.   24.  Upon information and belief, as part of its utilization of RevSpring, Defendant  conveyed information regarding the alleged Debt to RevSpring by electronic means.  4   25.  Upon information and belief, the information conveyed by Defendant to RevSpring  included Plaintiff’s status as a debtor, the precise amount of the alleged Debt, the account number,  the entity to which Plaintiff allegedly owed the debt, among other things.    26.  Defendant’s conveyance of the information regarding the alleged Debt to  RevSpring is a “communication” as that term is defined by 15 U.S.C. § 1692a(2).   27.  Upon information and belief, RevSpring then populated some or all this  information into a prewritten template, printed, and mailed the correspondence to Plaintiff at  Defendant’s direction.   28.  That correspondence, dated July 15, 2020, was received, and read by Plaintiff.  (A  true and accurate copy of that correspondence (the “Letter”) is annexed hereto as “Exhibit 1.”)   29.  The Letter, which conveyed information about the alleged Debt, is a  “communication” as that term is defined by 15 U.S.C. § 1692a(2).   30.  The Letter was the initial written communication Plaintiff received from Defendant  concerning the alleged Debt.  31.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     32.  15 U.S.C. § 1692c(b) provides that, subject to several exceptions not applicable  here, “a debt collector may not communicate, in connection with the collection of any debt,” with  anyone other than the consumer “without the prior consent of the consumer given directly to the  debt collector.”   33.  RevSpring does not fall within any of the exceptions provided for in 15 U.S.C. §  1692c(b).  5   34.  Plaintiff never consented to Defendant’s communication with RevSpring  concerning the alleged Debt.   35.  Plaintiff never consented to Defendant’s communication with RevSpring  concerning Plaintiff’s personal and/or confidential information.   36.  Plaintiff never consented to Defendant’s communication with anyone concerning  the alleged Debt or concerning Plaintiff’s personal and/or confidential information.   37.  Upon information and belief, Defendant has utilized RevSpring for these purposes  thousands of times.   38.  Defendant utilizes RevSpring in this regard for the sole purpose of maximizing its  profits.   39.  Defendant utilizes RevSpring without regard to the propriety and privacy of the  information which it discloses to such third-party.   40.  Defendant utilizes RevSpring with reckless disregard for the harm to Plaintiff and  other consumers that could result from Defendant’s unauthorized disclosure of such private and  sensitive information.   41.  Defendant violated 15 U.S.C. § 1692c(b) when it disclosed information about  Plaintiff’s alleged Debt to RevSpring.   42.  15 U.S.C. § 1692f provides that a debt collector may not use unfair or  unconscionable means to collect or attempt to collect any debt.     43.  The unauthorized disclosure of a consumer’s private and sensitive information is  both unfair and unconscionable.   44.  Defendant disclosed Plaintiff’s private and sensitive information to RevSpring.     45.  Defendant violated 15 U.S.C. § 1692f when it disclosed information about  6  Plaintiff’s alleged Debt to RevSpring.   46.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692c(b) and 1692f  and is liable to Plaintiff therefor.  47.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     48.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.   49.  As relevant here, 15 U.S.C. § 1692g(a)(1) requires the written notice provide a  statement of the amount of the debt.   50.  To comply with 15 U.S.C. § 1692g(a)(1), the statement of the amount of the debt  must accurately set forth the actual amount of the debt.   51.  A statement of the amount of the debt, when the debt is not owed at all by the  consumer, violates 15 U.S.C. § 1692g(a)(1).   52.  As set forth in paragraphs 15 through 18 of this Complaint, Plaintiff did not owe  the Claimed Amount.   53.  As such, Defendant did not accurately set forth the actual amount of the alleged  debt as required by 15 U.S.C. § 1692g(a)(1).    54.  In sum, Defendant’s statement of the amount of the alleged Debt, when Plaintiff  did not owe that amount, violates 15 U.S.C. § 1692g(a)(1).   55.  As also relevant here, 15 U.S.C. § 1692g(a)(2) requires the written notice to provide  a statement of the name of the creditor to whom the debt is owed.  7   56.  To comply with 15 U.S.C. § 1692g(a)(2), the statement of the name of the creditor  to whom the debt is owed must accurately set forth the name of the entity that actually owns the  debt.   57.  A statement of the name of the creditor to whom the debt is owed, when the  consumer does not owe money to the stated entity, violates 15 U.S.C. § 1692g(a)(2).   58.  As set forth in paragraphs 15 through 18 of this Complaint, Plaintiff did not owe  money to Verizon.     59.  As such, Defendant did not accurately set forth the name of the entity that actually  owns the debt as required by 15 U.S.C. § 1692g(a)(2).    60.  In sum, Defendant’s statement that Verizon was the name of the creditor to whom  the alleged debt was owed, when Plaintiff did not owe any money to Verizon, violates 15 U.S.C.  § 1692g(a)(2).   61.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692g, 1692g(a)(1) and  1692g(a)(2) and is liable to Plaintiff therefor.  62.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.    63.  15 U.S.C. § 1692e provides, generally, that a debt collector may not use any false,  deceptive, or misleading representation or means in connection with the collection of any debt.   64.  15 U.S.C. § 1692e(2)(A) prohibits the false representation of the character, amount,  or legal status of any debt.   65.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.    8   66.  An allegation by a debt collector that a consumer owes a debt to a certain entity  when the consumer does not owe a debt to that entity is a violation of 15 U.S.C. §§ 1692e,  1692e(2)(A) and 1692e(10).   67.  An allegation by a debt collector that a consumer owes a certain amount of money  when the consumer does not that amount is a violation of 15 U.S.C. §§ 1692e, 1692e(2)(A) and  1692e(10).   68.  As set forth in paragraphs 15 through 18 of this Complaint, Plaintiff did not owe  the Claimed Amount.   69.  As set forth in paragraphs 15 through 18 of this Complaint, Plaintiff did not owe  money to Verizon.     70.  As such, Defendant’s allegation that Plaintiff owed the Claimed Amount is a false,  deceptive, and/or misleading representation made in connection with the collection of the alleged  Debt in violation of 15 U.S.C. § 1692e.   71.  Defendant’s allegation that Plaintiff owed money to Verizon  is a false, deceptive,  and/or misleading representation made in connection with the collection of the alleged Debt in  violation of 15 U.S.C. § 1692e.   72.  Defendant’s allegation that Plaintiff owed the Claimed Amount is a false  representation of the character, amount, and/or legal status of the alleged Debt in violation of 15  U.S.C. § 1692e(2)(A).   73.  Defendant’s allegation that Plaintiff owed money to Verizon is a false  representation of the character, amount, and/or legal status of the alleged Debt in violation of 15  U.S.C. § 1692e(2)(A).  9   74.  Defendant’s allegation that Plaintiff owed the Claimed Amount is a false  representation made in an attempt to collect the alleged Debt in violation of 15 U.S.C. § 1692e(10).   75.  Defendant’s allegation that Plaintiff owed money to Verizon is a false  representation made in an attempt to collect the alleged Debt in violation of 15 U.S.C. § 1692e(10).   76.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692e, 1692e(2)(A)  and 1692e(10) and is liable to Plaintiff therefor.    77.  Plaintiff brings this action individually and as a class action on behalf of all  consumers similarly situated in Suffolk County, New York.   78.  Plaintiff seeks to certify a class of:  i. All consumers where Defendant sent information concerning the  consumer’s debt to a third-party vendor without obtaining the prior  consent of the consumer, which disclosure was made on or after a date  one year prior to the filing of this action to the present.   79.  This action seeks a finding that Defendant’s conduct violates the FDCPA and asks  that the Court award damages as authorized by 15 U.S.C. § 1692k.   80.  The Class consists of more than thirty-five persons.   81.  Plaintiff’s claims are typical of the claims of the Class.  Common questions of law  or fact raised by this action affect all members of the Class and predominate over any individual  issues.  Common relief is therefore sought on behalf of all members of the Class.  A class action is  superior to other available methods for the fair and efficient adjudication of this controversy.   82.  The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of the  Class, and a risk that any adjudications with respect to individual members of the Class would, as  a practical matter, either be dispositive of the interests of other members of the Class not party to  10  the adjudication, or substantially impair or impede their ability to protect their interests.  Defendant  has acted in a manner applicable to the Class as a whole such that declaratory relief is warranted.   83.  Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class is not extraordinarily difficult, and the factual and legal issues raised  by this action will not require extended contact with the members of the Class, because Defendant’s  conduct was perpetrated on all members of the Class and will be established by common proof.   Moreover, Plaintiff has retained counsel experienced in actions brought under consumer protection  laws.  Violation of 15 U.S.C. § 1692c(b) and § 1692f   Violation of 15 U.S.C. §§ 1692e, 1692e(2)(A) and 1692e(10)   Violation of 15 U.S.C. §§ 1692g, 1692g(a)(1), 1692g(a)(2)  