11. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   12. Some time prior to May 4, 2021, an obligation was allegedly incurred to CF MEDICAL  33. Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ. P. 23(a)  and 23(b)(3):   34. The Class consists of (a) all individuals in the State of Texas (b) whose information was  shared by Defendant to its mail house (c) in connection with a debt purportedly whose  original creditor was CF MEDICAL LLC, (d) during the one-year period preceding the  filing of the Complaint in this action.     36. Excluded from the Plaintiff Class are the Defendant and all officers, members, partners,  managers, directors, and employees of the Defendant and their respective immediate  families, and legal counsel for all parties to this action and all members of their immediate  families.   37. There are questions of law and fact common to the Plaintiff Class, which common issues  predominate over any issues involving only individual class members. The principal issue  is whether the Defendant’s practice, of sharing debtor’s personal and protected information  with its mail house, violates 15 U.S.C. §§ 1692c and 1692e.   38. The Plaintiff’s claims are typical of the class members, as all are based upon the same facts  and legal theories.   39. The Plaintiff will fairly and adequately protect the interests of the Plaintiff Class defined  in this complaint. The Plaintiff has retained counsel with experience in handling consumer  lawsuits, complex legal issues, and class actions, and neither the Plaintiff nor Plaintiff’s  attorneys have any interests, which might cause them not to vigorously pursue this action.   42. Depending on the outcome of further investigation and discovery, Plaintiff may, at the time  of class certification motion, seek to certify a class(es) only as to particular issues pursuant  to Fed. R. Civ. P. 23(c)(4).  43. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs above  herein with the same force and effect as if the same were set forth at length herein.   44. Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff violated  various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692c.    45. Pursuant to Section 15 U.S.C. §1692c of the FDCPA:  “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.” (emphasis added).   46. The Defendant violated said provision by conveying Plaintiff’s information to its mail  house in connection with the collection of Plaintiff’s debt, in violation of 15 U.S.C. §1692c.   47. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant’s conduct  violated Section 1692c et seq. of the FDCPA, statutory damages, costs and attorneys’ fees.   49. Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff violated  various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692f.   50. Defendant violated 15 U.S.C. § 1692f by using unfair means in connection with the  collection a debt, to wit, knowingly disclosing sensitive information about Plaintiff’s debt  to third parties not expressly authorized under the FDCPA.   51. 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.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692c et seq.  