13. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered “1” through “12” herein with the same force and effect as if the same were set  forth at length herein.   14. Some time prior to February 28, 2014, an obligation was allegedly incurred to Seventh  Avenue. (“Seventh”)   15. The Seventh 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 alleged Seventh obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   17. Seventh is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   18. Defendant contends that the Seventh debt is past due.   19. Defendant collects and attempts to collect debts incurred or alleged to have been incurred  for personal, family or household purposes on behalf of creditors using the United States  Postal Services, telephone and internet.   20. Seventh directly or through an intermediary contracted Defendant to collect the BIPG  debt.   21. On or about February 28, 2014, the Defendant caused to be delivered to the Plaintiff a  collection letter in an attempt to collect the alleged Seventh debt. See Exhibit A.   23. The February 28, 2014 letter is a “communication” as defined by 15 U.S.C. §1692a(2).   24. The Defendant’s February 28, 2014 letter states in part:  “If you would like to pay by credit card We accept Visa, Mastercard, and  Discover  Please Call 1-800-275-7176 Ext 602 There is a fee for credit card  payments.”   25. Defendant’s February 28, 2014 letter further states:  “Should you have any questions, or wish to pay by phone, call our courteous staff  at 1-800-275-7176 ext. 602.  There is a fee for check by phone.”   26. Upon information and belief, the Defendant has no legal or contractual right to charge a  fee for credit card payments or checks by phone.   27. The February 8, 2014 letter was sent in an envelope that contained a glassine window.   28. Visible through the glassine window was the Plaintiff’s name, Plaintiff’s address, and the  Plaintiff’s reference number with the Defendant.    29. The reference number constitutes personal identifying information.   30. The reference number is not meaningless – it is a piece of information capable of  identifying [the consumer] as a debtor, and its disclosure has the potential to cause harm  to a consumer that the FDCPA was enacted to address. Douglass v. Convergent  Outsourcing, 765 F. 3d 299 (Third Cir. 2014).   31. Defendant’s actions as described herein are part of a pattern and practice used to collect  consumer debts.   33. On information and belief, Defendant sent a written communication, in the form annexed  hereto as Exhibit A to at least 50 natural persons in the State of New Jersey within one  year of the date of this Complaint.  34. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered “1” through “34” herein with the same force and effect as if the same were set  forth at length herein.   35. Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated 15 U.S.C. § 1692f of the FDCPA.   36. Pursuant to 15 USC §1692f(1), a debt collector may not use unfair or unconscionable  means to collect or attempt to collect any debt.  Without limiting the general application  of the foregoing, the following conduct is a violation of this section:  (1) The collection  of any amount (including interest, fee, charge, or expense incidental to the principal  obligation) unless such amount is expressly authorized by the agreement creating the debt  or permitted by law.      37. The Defendant violated said section by advising the Plaintiff that they accept credit card  payments, directing him to their toll free number and informing him that there is a fee  associated with credit card payments.   39. Pursuant to 15 U.S.C. §1692f(8), a debt collector is prohibited from using any language  or symbol, other than the debt collector’s address, on any envelope when communicating  with the consumer by use of mails.   40. The Defendant violated said section by putting the Plaintiff’s reference number visible on  the February 28, 2014 letter.   41. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's conduct  violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692f et seq.  