10. This action arises out of Defendant’s attempts to collect a credit card debt incurred for personal, family or household purposes.  11. On or about July 7, 2020, Defendant Credit Control, LLC caused a letter vendor to send Plaintiff the letter in Exhibit A.  12. The letter bears markings that are characteristic of one generated by a letter vendor.  13. In order to have the letter vendor send Plaintiff the letter in Exhibit A, Defendant had to furnish the letter vendor with Plaintiff’s name and address, the status of Plaintiff as a debtor, details of Plaintiff’s alleged debt, and other personal information. -2-  14. The letter vendor then populated some or all of this information into a prewritten template, printed, and mailed the letter to Plaintiff.  15. 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.”  16. The sending of an electronic file containing information about Plaintiff’s  purported debt to a letter vendor is therefore a communication.   17. Defendant’s communication to the letter vendor 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.  18. Plaintiff  never consented to having Plaintiff’s personal and confidential information, concerning the debt or otherwise, shared with anyone else.  19.  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.”  20. The letter vendor used by Defendant as part of its debt collection effort against Plaintiff  does not fall within any permitted exception provided for in 15 U.S.C. §1692c(b).  21.  Due to Defendant’s communication to this letter vendor,  information about Plaintiff is within the possession of an unauthorized third-party.  22. 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  --  -3- 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).  23. Defendant unlawfully communicates with the unauthorized third-party letter vendor 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.  24. In its reckless pursuit of a business advantage, Defendant disregarded the known, negative effect that disclosing personal  information to an unauthorized third-party has on consumers. 25. Plaintiff incorporates paragraphs 1-24.  26. Defendant violated 15 U.S.C. §1692c(b) when it disclosed information about Plaintiff’s purported debt to the employees of an unauthorized third-party letter vendor in connection with the collection of the debt.  27. Defendant violated 15 U.S.C. §1692f by using unfair means in connection with the collection of a debt  –  disclosing personal information about Plaintiff  to third parties not expressly authorized under the FDCPA. 28. Plaintiff brings this action on behalf of a class.  29. The class consists of (a) all individuals in New York (b) with respect to whom Defendant had a letter prepared and sent by a letter vendor (c)  which letter was sent at any time during a period beginning one year prior to the filing of this action and ending 30 days after the filing of this action.    30. Plaintiff may alter the class definition to conform to developments in the case and discovery. -4-  31. On information and belief, based on the size of Defendant’s business operations and the use of form letters, there are more than 40 members of the class, and the  class is so numerous that joinder of all members is not practicable.  32. There are questions of law and fact common to the class members, which common  questions predominate over any questions relating to individual class members.  The predominant common questions are whether Defendant’s practice as described above violates the