15.  Defendant alleges Plaintiff owes a debt (“the alleged Debt”).   16.  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.   17.  The alleged Debt does not arise from any business enterprise of Plaintiff.   18.  The alleged Debt is a “debt” as that term is defined by 15 U.S.C. § 1692a(5).   19.  At an exact time known only to Defendant, the alleged Debt was assigned or  otherwise transferred to Defendant for collection.    20.  At the time the alleged Debt was assigned or otherwise transferred to Defendant for  collection, the alleged Debt was in default.   21.  In its efforts to collect the alleged Debt, Defendant decided to contact Plaintiff by  written correspondence.   22.  Upon information and belief, rather than preparing and mailing such written  correspondence to Plaintiff on its own, Defendant decided to utilize a third-party in Wixom,  Michigan, to perform such activities on its behalf.   23.  As part of its utilization of the third-party, Defendant conveyed information  regarding the alleged Debt to the third-party.   24.  The information conveyed by Defendant to the third-party included Plaintiff’s  status as a debtor, the precise amount of the alleged Debt, the entity to which Plaintiff allegedly  owed the debt, among other things.    25.  Defendant’s conveyance of the information regarding the alleged Debt to the third- party is a “communication” as that term is defined by 15 U.S.C. § 1692a(2).  4   26.  The third-party then populated some or all this information into a prewritten  template, printed, and mailed the letter to Plaintiff at Defendant’s direction.   27.  That letter, dated August 13, 2020, was received, and read by Plaintiff.  (A true and  accurate copy of that collection letter (the “Letter”) is annexed hereto as “Exhibit 1.”)   28.  The Letter, which conveyed information about the alleged Debt, is a  “communication” as that term is defined by 15 U.S.C. § 1692a(2).   29.  The Letter was the initial written communication Plaintiff received from Defendant  concerning the alleged Debt.  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 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  concerning the alleged Debt.   34.  Plaintiff never consented to Defendant’s communication with the third-party  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.  5   36.  Upon information and belief, Defendant has utilized a third-party for these purposes  thousands of times.   37.  Defendant utilizes a third-party in this regard for the sole purpose of maximizing  its profits.   38.  Defendant utilizes a third-party without regard to the propriety and privacy of the  information which it discloses to such third-party.   39.  Defendant utilizes a third-party 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.   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.     44.  Defendant violated 15 U.S.C. § 1692f when it disclosed information about  Plaintiff’s alleged Debt to the third-party.   45.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692c(b) and 1692f  and is liable to Plaintiff therefor.  46.  Plaintiff brings this action individually and as a class action on behalf of all  consumers similarly situated in the State of New York.   47.  Plaintiff seeks to certify a class of:  6  i. All consumers where Defendant sent information concerning the  consumer’s debt to a third-party 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.   48.  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.   49.  The Class consists of more than thirty-five persons.   50.  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.   51.  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.   52.  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.  Violation of 15 U.S.C. § 1692c(b) and § 1692f  