22.  Defendants allege Plaintiff owes $851.83 to Bureaus Investment Group Portfolio  No 15, LLC (“the alleged Debt”).    23.  The alleged Debt does not arise from any business enterprise of Plaintiff.   24.  The alleged Debt is a “debt” as that term is defined by 15 U.S.C. § 1692a(5).  4   25.  At an exact time known only to Defendants, the alleged Debt was assigned or  otherwise transferred by Bureaus Investment Group Portfolio No 15, LLC to D & A Services, LLC  of IL for collection.    26.  At the time the alleged Debt was assigned or otherwise transferred to D & A  Services, LLC of IL for collection, the alleged Debt was in default.   27.  In their efforts to collect the alleged Debt, Defendants decided to contact Plaintiff  by written correspondence.   28.  Rather than preparing and mailing such written correspondence to Plaintiff on their  own, Defendants decided to utilize a third-party vendor to perform such activities on their behalf.   29.  As part of their utilization of the third-party vendor, Defendants conveyed  information regarding the alleged Debts to the third-party vendors by electronic means.   30.  The information conveyed by Defendants to the third-party vendor 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.    31.  Defendants’ conveyance of the information regarding the alleged Debt to the third- party vendor is a “communication” as that term is defined by 15 U.S.C. § 1692a(2).   32.  The third-party vendor then populated some or all this information into a prewritten  template, printed, and mailed the correspondence to Plaintiff at Defendants’ direction.   33.  That correspondence, dated October 8, 2020, was received and read by Plaintiff.   (A true and accurate copy of that correspondence (the “Letter”) is annexed hereto as “Exhibit 1.”)   34.  The Letter, which conveyed information about the alleged Debt, is a  “communication” as that term is defined by 15 U.S.C. § 1692a(2).  5   35.  The Letter was the initial written communication Plaintiff received from  Defendants concerning the alleged Debt.  36.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     37.  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.”   38.  The third-party vendor does not fall within any of the exceptions provided for in 15  U.S.C. § 1692c(b).   39.  Plaintiff never consented to Defendant’s communication with the third-party  vendor concerning the alleged Debt.   40.  Plaintiff never consented to Defendant’s communication with the third-party  vendor concerning Plaintiff’s personal and/or confidential information.   41.  Plaintiff never consented to Defendant’s communication with anyone concerning  the alleged Debt or concerning Plaintiff’s personal and/or confidential information.   42.  Upon information and belief, Defendant has utilized a third-party vendor for these  purposes thousands of times.   43.  Defendant utilizes a third-party vendor in this regard for the sole purpose of  maximizing its profits.   44.  Defendant utilizes a third-party vendor without regard to the propriety and privacy  of the information which it discloses to such third-party.   45.  Defendant utilizes a third-party vendor with reckless disregard for the harm to  6  Plaintiff and other consumers that could result from Defendant’s unauthorized disclosure of such  private and sensitive information.   46.  Defendant violated 15 U.S.C. § 1692c(b) when it disclosed information about  Plaintiff’s alleged Debt to the third-party vendor.   47.  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.     48.  The unauthorized disclosure of a consumer’s private and sensitive information is  both unfair and unconscionable.   49.  Defendant disclosed Plaintiff’s private and sensitive information to the third-party  vendor.     50.  Defendant violated 15 U.S.C. § 1692c(b) when it disclosed information about  Plaintiff’s alleged Debt to the third-party vendor.   51.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692c(b) and 1692f  and is liable to Plaintiff therefor.  52.  Plaintiff brings this action individually and as a class action on behalf of all  consumers similarly situated in the County of Suffolk.   53.  Plaintiff seeks to certify a class of:  i. All consumers where Defendants 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.   54.  This action seeks a finding that Defendants’ conduct violates the FDCPA and asks  that the Court award damages as authorized by 15 U.S.C. § 1692k.   55.  The Class consists of more than thirty-five persons.  7   56.  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.   57.  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  the adjudication, or substantially impair or impede their ability to protect their interests.  Defendants  have acted in a manner applicable to the Class as a whole such that declaratory relief is warranted.   58.  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 Defendants’  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  