- 2 -   11.  This Action is properly maintained as a class action. The Class consists of:   All New Jersey consumers who were sent letters and/or notices from Tate &  Kirlin Associates, concerning a debt owed to ADT Security Systems, Inc.,  which:  a.  used a symbol and/or a string of numbers on or visible through the   window of the envelope that when read reveals the addressee's   account number.   The Class period begins one year to the filing of this Action.   13. Plaintiff is at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. §1692a(3).   14. On or about August 15, 2014, Plaintiff allegedly incurred a financial obligation to  ADT Security Systems, Inc. ("ADT").   15. The ADT obligation arose out of a transaction, in which money, property, insurance  or services, which are the subject of the transaction, are primarily for personal, family or  household purposes.   16. The ADT obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   17. ADT is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   18. At some time prior to August 15, 2014, the ADT obligation was placed with TKA  for the purpose of collection.   19. At the time the ADT obligation was placed with TKA, the balance was past due.   20. On or about August 15, 2014, TKA caused to be delivered to Plaintiff a letter  addressed to Plaintiff.  Exhibit A.  - 5 -   22. The August 15, 2014 letter is a “communication” as defined by 15 U.S.C.  §1692a(2).   23. The August 15, 2014 letter was sent or caused to be sent by persons employed by  TKA as a “debt collector” as defined by 15 U.S.C. §1692a(6).   24. The August 15, 2014 letter was mailed in a window envelope.   25. The envelope provide a window in the top left corner which displayed the follow:  2810 Southampton Road  Philadelphia, PA 19154-1207  34. Plaintiff repeats the allegations contained in paragraphs 1 through 33 as if the same  were set forth at length.   35. Section 1692f et seq. of the FDCPA prohibits a debt collector from using unfair or  unconscionable means to collect or attempt to collect any debt.   36. TKA violated 15 U.S.C. §1692f by:  a.  using unfair and unconscionable collection practices in connection with   the collection of a  debt;  b.  using language and symbol on envelopes mailed to consumers that reveal   information other than the debt collector's address, in violation of 15   U.S.C. §1692f(8).   FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692  VIOLATION OF 15 U.S.C. §1692f  