113.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.  114.  Count II is brought on behalf of Plaintiff Maloney.  115.  Exhibit A falsely threatens to send Maloney’s account to an attorney and/or  threaten a lawsuit against Plaintiff if Plaintiff does not pay or call Midland by a specified date.   116.  At the time Exhibit A and Exhibit B were sent, Midland did not intend to file a  lawsuit against Maloney even if Maloney did not pay or call by such date.  117.  Defendants’ conduct violates 15 U.S.C. §§ 1692e, 1692e(5), 1692e(10), and  1692f.  118.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.  119.  Count III is brought on behalf of Plaintiff Maloney.  120.  Exhibit A threatens and implies legal action notwithstanding the fact that Midland  did not intend to forward the letter to an attorney network even if Maloney did not pay or call by  the date specified in the letters.  121.  Such conduct violates Wis. Stat. §§ 427.104(1)(L) and 427.104(1)(h).  45.  Plaintiff Debbie Maloney entered into a consumer transaction with Comenity  Capital. ("Comenity") for a personal credit card.   47.  Prior to October 7, 2016, and after Plaintiff Maloney’s account with Comenity  was in default, Comenity sold or otherwise assigned the ownership rights to Plaintiff’s account to  Midland Funding.   48.  On or about October 7, 2016, MCM mailed a debt collection letter to Plaintiff  Maloney regarding an alleged debt, allegedly owed to Midland Funding and originally owed to  Comenity. A copy of this letter is attached to this complaint as Exhibit A and a copy of the  envelope in which it was received is attached as Exhibit B.   49.  The alleged debt identified in Exhibit A was for a personal credit card account  used only for personal, family or household purposes.   50.  Upon information and belief, Exhibit A is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.   51.  Upon information and belief, Exhibit A is a form debt collection letter used by  Midland to attempt to collect alleged debts.   52.  Upon information and belief, Exhibit B is a form debt collection envelope used by  Midland to attempt to collect alleged debts.   53.  Exhibit A contains bold, all-capitalized text at the top of the letter:   55.  Exhibit A also contains the following:   56.  Exhibit A also contains the following:   57.  The above language is false, misleading and confusing to the unsophisticated  consumer.    58.  At the time Exhibit A was sent to Plaintiff Maloney, Midland did not intend to sue  Plaintiff Maloney, even if no payments were made on the account by 11-21-2016.   59.  Despite the clear language threatening to send the account to “an attorney in your  state . . . if we don't hear from you or receive payment by 11-21-2016,” Midland did not file a  lawsuit against Plaintiff Maloney.   60.  A search of CCAP on September 29, 2017 shows no civil actions filed by  Midland against Plaintiff Maloney in Wisconsin.    61.  An unsophisticated consumer would understand that Exhibit A threatens a  lawsuit, and/or implies that legal action will be taken unless payment or a phone call is made by  11-21-2016.    63.  Even indirect or oblique threats give rise to liability, provided they indicate that  “legal action is underway or contemplated in the near future.” Jenkins, 999 F. Supp. At 1136.   64.  The unsophisticated consumer would interpret the “pre-legal status” and the  statement that “if we don't hear from you or receive payment by 11-21-2016, we may proceed  with forwarding this account to an attorney” as a threat that the account is on a litigation track.    65.  The threat of litigation in Midland’s letter is false and misleading and exists only  to unfairly scare consumers.   66.  In fact, Plaintiff’s account was not forwarded to an attorney network.    67.  Additionally, Exhibit B included extraneous text.    68.  The exterior face of Exhibit B, containing Plaintiff's mailing address, also states  in the upper right hand corner, "U.S.POSTAGE PAID MCM."   Vega Letter   69.  Plaintiff Amy Vega entered into a consumer transaction with Synchrony Bank.  ("Synchrony") for a personal credit card.   70.  Prior to October 12, 2016, Plaintiff Vega’s account with Synchrony went into  default.   72.  On or about October 12, 2016, MCM mailed a debt collection letter to Plaintiff  Vega regarding an alleged debt, allegedly owed to Midland Funding and originally owed to  Synchrony. A copy of this letter is attached to this complaint as Exhibit C and a copy of the  envelope in which it was received is attached as Exhibit D.   73.  The alleged debt identified in Exhibit C was for a personal credit card account  used only for personal, family or household purposes.   74.  Upon information and belief, Exhibit C is a form letter, generated by computer,  and with the information specific to Plaintiffs inserted by computer.   75.  Upon information and belief, Exhibit C is a form debt collection letter used by  Midland to attempt to collect alleged debts.   76.  Upon information and belief, Exhibit D is a form debt collection envelope used by  Midland to attempt to collect alleged debts.   77.  Exhibit D included extraneous text.    78.  The exterior face of Exhibit D containing Plaintiffs’ mailing address also states  “Time Sensitive Document” and, in the upper right hand corner, “U.S. POSTAGE PAID MCM.”  Plaintiff Czarnecki entered into a consumer transaction with Comenity Bank (“Comenity”) for a  personal credit card.  Czarnecki Letter   79.  Prior to January 20, 2017, Plaintiff Czarnecki’s account with Comenity went into  default.   81.  On or about January 20, 2017, MCM mailed a debt collection letter to Plaintiff  Czarnecki regarding an alleged debt, allegedly owed to Midland Funding and originally owed to  Comenity. A copy of this letter is attached to this complaint as Exhibit E and a copy of the  envelope in which it was received is attached as Exhibit F.   82.  The alleged debt identified in Exhibit E was for a personal credit card account  used only for personal, family or household purposes.   83.  Upon information and belief, Exhibit E is a form letter, generated by computer,  and with the information specific to Plaintiffs inserted by computer.   84.  Upon information and belief, Exhibit E is a form debt collection letter used by  Midland to attempt to collect alleged debts.   85.  Upon information and belief, Exhibit F is a form debt collection envelope used by  Midland to attempt to collect alleged debts.   86.  Exhibit F included extraneous text.    87.  The exterior face of Exhibit F containing Plaintiffs’ mailing address also states  “Time Sensitive Document” and, in the upper right hand corner, “U.S. POSTAGE PAID MCM.”   88.  The Fair Debt Collection Practices Act prohibits unfair debt collection practices.  15 U.S.C. § 1692f.   90.  The language on Exhibit B, Exhibit D, and Exhibit F violates the plain language  of 15 U.S.C. § 1692f(8). The statute contains no exceptions – any extraneous text on the  envelope or on the outside of a self-mailer violates 15 U.S.C. § 1692f(8).   91.  Moreover, the extraneous text in Exhibit D and Exhibit F indicates that the letters  are, in fact, debt collection letters. See Douglass v. Convergent Outsourcing, 765 F.3d 299, 303- 04 (3d Cir. 2014) (disclosure through window envelope “implicates a core concern animating the  FDCPA—the invasion of privacy.”); Peter v. GC Services L.P., 310 F.3d 344, 351 (5th Cir.  2002).   92.  In Peter, for example, the Fifth Circuit held that text on the envelope  impersonating the U.S. Department of Education1 “implicates this core concern of the FDCPA  [impersonating public officials].” Peter, 310 F.3d at 351-52.   93.  Likewise, in Douglass, the Third Circuit held that a collection letter displaying the  consumer’s account number and a QR code2 that linked to the consumer’s alleged debt, through  a “glassine” window envelope, violated § 1692f(8). Douglass, 765 F.3d at 303 (“Convergent's  disclosure implicates a core concern animating the FDCPA—the invasion of privacy.”)   94.  As in Douglass and Peter, the language on Exhibit B, Exhibit D, and Exhibit F  implicates a core concern animating the FDCPA – privacy.   96.  For example, 15 U.S.C. § 1692f(7) prohibits: “Communicating with a consumer  regarding a debt by post card.” The content of a post card is visible to anyone who views it.   97.  Likewise, 15 U.S.C. § 1692c(b) prohibits most communications with third parties:  (b) Communication with third parties   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 postjudgment  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.    98.  15 U.S.C. § 1692b allows but strictly regulates communications with third parties  for the purpose of obtaining the consumer’s location information, including explicit prohibitions  against stating “that such consumer owes any debt,” and using “any language or symbol on any  envelope or in the contents of any communication effected by the mails or telegram that  indicates that the debt collector is in the debt collection business or that the communication  relates to the collection of a debt.” 15 U.S.C. §§ 1692b(2), 1692b(5).   Maloney Letter  