31.  Plaintiff, RICKY ESPINAL, repeats and re-alleges Paragraphs 14-30  as though fully set forth.   32.  MCM used a third-party vendor to mail MCM’s Collection Letters to  Plaintiff as well as other similarly formatted Collection Letters to other Florida  consumers with addresses within this Judicial District.   33.  In using a form/template collection letter to generate MCM’s  Collection Letters, MCM caused Plaintiff’s name, address, the name of the  creditor, the amount owed, the so-called “transaction date”, the account number  for the creditor, and MCM’s reference number to be inserted into form/template  collection letter.   35.  Plaintiff did not consent to MCM communicating Plaintiff’s personal  information and Plaintiff’s status as an alleged debtor with MCM’s letter vendor.   36.  Sharing personal information of a consumer with third-parties  violates Section 1692c(b) of the FDCPA. See, Hunstein v. Preferred Collection and  Management Services, Inc., 994 F.3d 1341 (11th Cir. April 21, 2021).   37.  Section 1692c(b) of the FDCPA, titled “Communication with third  parties,” with very limited exceptions, prohibits debt collectors from disclosing  to third-parties that a “consumer” is obligated to pay debt to a creditor  communicated to third-parties without consent of the consumer. See, Hunstein  v. Preferred Collection & Mgmt. Servs., 994 F.3d 1341, 2021 U.S. App. LEXIS  11648 (11th Cir. 2021).   38.  Section 1692c(b), entitled “Communication with third parties,”  states as follows:   Except as provided in section 1692b of this title, without the prior  consent of the consumer given directly to the debt collector, ... 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.   15 U.S.C. § 1692c(b) (emphasis supplied).    40.  Section 1692b relates to the manner in which a debt collector may  lawfully communicate "with any person other than the consumer for the purpose  of acquiring location information." 15 U.S.C. § 1692b (emphasis supplied).    41.  Section 1692a(7) defines the term “location information” to mean “a  consumer’s place of abode and his telephone number at such place, or his place  of employment”.   42.  Defendant’s transmission of Plaintiff’s personal information and  Plaintiff’s status as a debtor to Defendant’s letter vendor did not constitute an  attempt to obtain “location information” related to Plaintiff.   44.   “[T]he existence of a right of privacy is now recognized in the great  majority of the American jurisdictions that have considered the question." Id.  (quoting Restatement (Second) of Torts § 652A cmt. a. (Am. Law Inst. 1977)).   45.  “[T]he term ‘invasion of privacy’ comprises an identifiable family of  common-law torts—including, most relevantly here, ‘public disclosure of private  facts.’ Invasion of Privacy, Black's Law Dictionary 952 (10th ed. 2014).” Id. at *8- *9.    46.  “It is hornbook law that ‘[o]ne who gives publicity to a matter  concerning the private life of another is subject to liability to the other for  invasion of his privacy, if the matter publicized is of a kind that (a) would be  highly offensive to a reasonable person, and (b) is not of legitimate concern to  the public.’ Restatement (Second) of Torts § 652D (1977).” Id. at *9.    48.  The tort of “invasion of privacy” comprises an identifiable family of  common-law torts—including, most relevantly here, “public disclosure of private  facts.” INVASION OF PRIVACY, BLACK’S LAW DICTIONARY 952 (10th ed. 2014). It is  hornbook law that “[o]ne who gives publicity to a matter concerning the private  life of another is subject to liability to the other for invasion of his privacy, if the  matter publicized is of a kind that (a) would be highly offensive to a reasonable  person, and (b) is not of legitimate concern to the public.” RESTATEMENT (SECOND)  OF TORTS § 652D (1977). See also, 77 C.J.S. RIGHT OF PRIVACY AND PUBLICITY § 32;  78.  Plaintiff RICKY ESPINAL repeats and re-alleges Paragraphs 14-30 as  though fully set forth.   79.  In order to gain a competitive advantage over other debt collectors,  and in defiance of the prohibitions set forth by Section 1692f(8) of the FDCPA,  MCM caused form collection letters to be mailed to consumers like Plaintiff where  the subject envelopes are marked with the words “TIME SENSITIVE  DOCUMENT” or “Extremely Urgent”.   81.  MCM knows that by enclosing collection letters inside of envelopes  marked with the words “TIME SENSITIVE DOCUMENT” or Extremely Urgent,  consumers are more likely read the enclosed letter and pay the subject debt –  than if the letter was sent in a plain envelope.   82.  MCM knows that by enclosing collection letters inside of envelopes  marked with the words “TIME SENSITIVE DOCUMENT” or “Extremely  Urgent”, consumers are more likely read the enclosed letter and call Defendant  regarding the consumer’s debt.    83.  For example, MCM’s Collection Letters informed Plaintiff that he  could only take advantage of a certain discounted payment option if Plaintiff  called a designated telephone number.   84.  MCM knows that enclosing collection letters inside of envelopes  marked with the words “TIME SENSITIVE DOCUMENT” or “Extremely Urgent”  leads to increased connections with consumers in comparison to when MCM  caused collection letters to be mailed inside of plain envelopes.   85.  MCM has determined that it collects more money from consumers  when it sends letters enclosed within envelopes marked with the words, “TIME  SENSITIVE DOCUMENT” or “Extremely Urgent” in comparison to when MCM  caused collection letters to be mailed inside of plain envelopes.   87.  As discussed above, MCM has caused numerous Collection Letters  to be sent to Plaintiff in an attempt to collection the Subject Debt.   88.  At least one of MCM’s Collection Letters was mailed to Plaintiff inside  of an envelope that contained the words “TIME SENSITIVE DOCUMENT” on its  exterior in bold font.   89.  At least one of MCM’s Collection Letters was mailed to Plaintiff inside  of an envelope that contained the words “Extremely Urgent” on its exterior in  bold blue colored font.   90.  When Plaintiff observed the words “TIME SENSITIVE DOCUMENT”  and “Extremely Urgent”, Plaintiff’s attention was immediately drawn to these  words.   91.  Reading  the  words 