15.  On June 2, 2020 Plaintiff received medical services from Good Samaritan Hospital.    16.  Thereafter, Good Samaritan Hospital claimed Plaintiff incurred a debt of $150.00  for the medical services (“the alleged Debt”).    17.  The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of a  transaction in which the money, property, insurance, or services which are the subject of the  transaction are primarily for personal, family, or household purposes.   18.  The alleged Debt does not arise from any business enterprise of Plaintiff.   19.  The alleged Debt is a “debt” as that term is defined by 15 U.S.C. § 1692a(5).   20.  At an exact time known only to Defendant, the alleged Debt was assigned or  otherwise transferred to Defendant for collection.    21.  At the time the alleged Debt was assigned or otherwise transferred to Defendant for  collection, the alleged Debt was in default.   22.  In its efforts to collect the alleged Debt, Defendant decided to contact Plaintiff by  written correspondence.   23.  Upon information and belief, rather than preparing and mailing such written  correspondence to Plaintiff on its own, Defendant decided to utilize a third-party vendor to perform  such activities on its behalf.   24.  Upon information and belief, as part of its utilization of the third-party vendor,  Defendant conveyed information regarding the alleged Debt to the third-party vendor.  4   25.  Upon information and belief, the information conveyed by Defendant to the third- party vendor included Plaintiff’s status as a debtor, the precise amount of the alleged Debt, the  entity to which Plaintiff allegedly owed the debt, and the fact that the alleged Debt concerned  Plaintiff’s medical treatment, among other things.    26.  Defendant’s conveyance of the information regarding the alleged Debt to the third- party vendor is a “communication” as that term is defined by 15 U.S.C. § 1692a(2).   27.  Upon information and belief, the third-party vendor then populated some or all this  information into a prewritten template, printed, and mailed the letter to Plaintiff at Defendant’s  direction.   28.  That letter, dated December 1, 2020, was received and read by Plaintiff.  (A true  and accurate copy of that collection letter (the “Letter”) is annexed hereto as “Exhibit 1.”)   29.  The Letter, which conveyed information about the alleged Debt, is a  “communication” as that term is defined by 15 U.S.C. § 1692a(2).  30.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     31.  15 U.S.C. § 1692c(b) provides that, subject to several exceptions not applicable  here, “a debt collector may not communicate, in connection with the collection of any debt,” with  anyone other than the consumer “without the prior consent of the consumer given directly to the  debt collector.”   32.  The third-party vendor does not fall within any of the exceptions provided for in 15  U.S.C. § 1692c(b).   33.  Plaintiff never consented to Defendant’s communication with the third-party  vendor concerning the alleged Debt.  5   34.  Plaintiff never consented to Defendant’s communication with the third-party  vendor concerning Plaintiff’s personal and/or confidential information.   35.  Plaintiff never consented to Defendant’s communication with anyone concerning  the alleged Debt or concerning Plaintiff’s personal and/or confidential information.   36.  Upon information and belief, Defendant has utilized a third-party vendor for these  purposes thousands of times.   37.  Defendant utilizes a third-party vendor in this regard for the sole purpose of  maximizing its profits.   38.  Defendant utilizes a third-party vendor without regard to the propriety and privacy  of the information which it discloses to such third-party.   39.  Defendant utilizes a third-party vendor with reckless disregard for the harm to  Plaintiff and other consumers that could result from Defendant’s unauthorized disclosure of such  private and sensitive information.   40.  Defendant violated 15 U.S.C. § 1692c(b) when it disclosed information about  Plaintiff’s alleged Debt to the third-party vendor.   41.  15 U.S.C. § 1692f provides that a debt collector may not use unfair or  unconscionable means to collect or attempt to collect any debt.     42.  The unauthorized disclosure of a consumer’s private and sensitive information is  both unfair and unconscionable.   43.  Defendant disclosed Plaintiff’s private and sensitive information to the third-party  vendor.     44.  Defendant violated 15 U.S.C. § 1692f when it disclosed information about  Plaintiff’s alleged Debt to the third-party vendor.  6   45.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692c(b) and 1692f  and is liable to Plaintiff therefor.  46.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.   47.  15 U.S.C. § 1692e provides, generally, that a debt collector may not use any false,  deceptive, or misleading representation or means in connection with the collection of any debt.    48.  15 U.S.C. § 1692e(5) prohibits the use of threats to take any action that are not  intended to be undertaken.    49.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     50.  A debt collection practice can be a “false, deceptive, or misleading” practice in  violation of 15 U.S.C. § 1692e even if it does not fall within any of the subsections of 15 U.S.C. §  1692e.      51.  A collection letter violates 15 U.S.C. § 1692e if, in the eyes of the least  sophisticated consumer, it is open to more than one reasonable interpretation, at least one of which  is inaccurate.   52.  The Letter states the “Due Date” for payment as December 11, 2020.   53.  The Letter further states that, “if the account is not resolved, we will assume that  you have no intention of settling this outstanding debt.”   54.  The Letter makes it appear that the payment would need to be made by the above- mentioned date or it will not be accepted.   55.  However, the Defendant continues to send more of these letters with the same false  threat after the expiry of the due date.   7   56.  Plaintiff has the interest and right to be free from false threats pertaining to actions  that are not intended to be undertaken.   57.  Plaintiff has the interest and right to be free from deceptive and/or misleading  communications from debt collectors, including Defendant.     58.  As such, Defendant’s representation that payment to be accepted can only be made  till the due date, is a false, deceptive, and/or misleading representation made in connection with  the collection of the alleged debt in violation of 15 U.S.C. § 1692e.   59.  Defendant’s representation that payment to be accepted can only be made till the  due date is a threat that to signify the payment window will close, which is false threat not intended  to be acted upon in violation of 15 U.S.C. § 1692e(5).   60.  Defendant’s allegation that payment to be accepted can only be made till the due  date is a false representation made in an attempt to collect the alleged debt in violation of 15 U.S.C.  § 1692e(10).   61.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692e, 1692e(5) and  1692e(10) and is liable to Plaintiff therefor.  62.  Plaintiff brings this action individually and as a class action on behalf of all  consumers similarly situated in the State of New York.   63.  Plaintiff seeks to certify two classes of:  i. All consumers where Defendant sent information concerning the  consumer’s debt to a third-party vendor without obtaining the prior  consent of the consumer, which disclosure was made on or after a date  one year prior to the filing of this action to the present.  ii. All consumers to whom Defendant sent a collection letter with  payment due dates, only to send subsequent collection letters with  additional due dates, which letter was sent on or after a date one year  prior to the filing of this action to the present.  8   64.  This action seeks a finding that Defendant’s conduct violates the FDCPA and asks  that the Court award damages as authorized by 15 U.S.C. § 1692k.   65.  The Class consists of more than thirty-five persons.   66.  Plaintiff’s claims are typical of the claims of the Class.  Common questions of law  or fact raised by this action affect all members of the Class and predominate over any individual  issues.  Common relief is therefore sought on behalf of all members of the Class.  A class action is  superior to other available methods for the fair and efficient adjudication of this controversy.   67.  The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of the  Class, and a risk that any adjudications with respect to individual members of the Class would, as  a practical matter, either be dispositive of the interests of other members of the Class not party to  the adjudication, or substantially impair or impede their ability to protect their interests.  Defendant  has acted in a manner applicable to the Class as a whole such that declaratory relief is warranted.   68.  Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class is not extraordinarily difficult, and the factual and legal issues raised  by this action will not require extended contact with the members of the Class, because Defendant’s  conduct was perpetrated on all members of the Class and will be established by common proof.   Moreover, Plaintiff has retained counsel experienced in actions brought under consumer protection  laws.  Violations of 15 U.S.C. §§ 1692e and 1692e(10)   Violation of 15 U.S.C. § 1692c(b) and § 1692f  