11.  On or about July 20, 2016, Greenspoon sent LaPan a letter containing a  "NOTICE OF DEFAULT AND ELECTION TO SELL UNDER DEED OF TRUST"  ("Default Notice"), an insert titled "FAIR DEBT COLLECTION PRACTICES ACT  DISCLOSURE" ("FDCPA Notice") and an "EXHIBIT A" (the "List"). The Default Notice  was pro-forma, containing repeated references to the List. Exhibit 1.1   12.  The Notice of Default, FDCPA Notice and List alleged that Plaintiff owed  $41,805.00 to "ELDORADO DEVELOPMENT CORP." Exhibit 1, page 5.   14.  The List alleged that LaPan, together with Francis Brooks, had defaulted  on 5/19/2014 and owed $41,805.00. Exhibit 1, page 7.   15.  Plaintiff demanded validation of the debt from Greenspoon on August 2,  2016. Exhibit 2.   16.  Greenspoon replied on August 13, 2016, and attached a printout showing a  current balance less than $8,000.00. Greenspoon offered no explanation or justification  for the $41,805.00 amount. Exhibit 3.   17.  Defendant sent .substantially the same letter again in October 2016, again  attaching the same list of debtors.   18.  The alleged debt related to a Timeshare that Plaintiff and Brooks  purchased in 2013 for the purpose of taking vacations there.   19.  On information and belief, Greenspoon is engaged in the collection of  consumer debts relating to timeshares.   21.  On information and belief, Greenspoon has, or had, a policy or practice of  mailing to alleged debtors, as an attempt to collect a debt, a Default Notice, FDCPA  Notice and List similar to those sent to Plaintiff, containing un-redacted lists of debtors,  dates and amounts of alleged debts.   22.  On information and belief,. Greenspoon has recorded many such pro- forma Notices of Default or Notices of Default and Election to Sell in the land records of  Clark County Nevada, in the past year. For the property parcel to which the Default  Notice and List naming Plaintiff was related, those filings included:  a. Document Number 201701110002120, a Notice of Default containing the  names of 123 individuals, filed on January 11, 2017.  b. Document Number 201612220000629, a Notice of Default containing the  names of 497 individuals, filed on December 22, 2016.  c. Document Number 201607130001965, a Notice of Default & Election to  Sell containing the names of 425 individuals, filed on July 13, 2016.   23.  Greenspoon has therefore told hundreds of consumers about the debts of  hundreds of other consumers.   24.  Plaintiff, and the Class, have suffered concrete and particularized injuries  as a result of Defendant's illegal behavior. The harm they have suffered is actual, not  hypothetical. The harm consists of invasion of privacy in a form - publication of debtors  lists - which is explicitly outlawed by federal and state law.   26.  Invasion of privacy is a concrete injury traditionally actionable at common  law. Invasion of privacy is actionable in most states and under the Restatement of Torts  analysis. Further, even if invasion of privacy were not a well-established cause of action  at common law, part of the express purpose of the FDCP A was to protect the privacy of  alleged debtors.   27.  Invasion of privacy is identified explicitly by Congress as an injury:  "Abusive debt collection practices contribute to the number of personal bankruptcies, to  marital instability, to the loss of jobs, and to invasions of individual privacy." 15 U.S.C. §  1692(a); "Existing laws and procedures for redressing these injuries are inadequate to  protect consumers." 15 U.S.C. § 1692(b). Thus, as one court concluded that a violation  of 15 U.S.C. , "both history and the judgment of Congress demonstrate that the unlawful  disclosure of legally protected information is a concrete harm that is sufficient to confer  standing." Daubert v. NRA Grp., LLC, No. 3:15-CV-00718, 2016 WL 4245560, at *4  (M.D. Pa. Aug. 11, 2016) citing In Re Nickelodeon Consumer Privacy Litig., 827 F.3d  262, 274 (3d Cir. 2016).   28.  The injury suffered by Plaintiff and Class is particularized, in that it is  personal to them and not an injury suffered by the body politic. Strubel v. Co"!enity  Bank, 842 F.3d 181, 188 (2d Cir. 2016).   29.  The injury suffered by Plaintiff and the Class is actual and not hypothetical  because their privacy has actually been harmed by Defendant's illegal disclosure of  information to third parties.  30.  This action is brought as a class action under Fed. R. Civ. P., Rule 23(b)(3).   32.  The named Plaintiff falls within the Class definition and is a Class  Member.   33.  The particular members of the Class are capable of being described  without managerial or administrative problems. The members of the Class are readily  identifiable from the information and records in the possession, custody or control of  the Defendant, since Defendant sent the offending communications.   34.  Upon information and belief, the Class is sufficiently numerous such that  individual joinder of all members is impractical. The three Notices identified above  listed the names of over 1,000 individuals in total.   36.  The Plaintiffs claims are the same as each member of the Class and are  based on the same legal and factual theories. There is nothing unusual about the  Plaintiff to warrant a material difference between her claims and the claims of the  members of the class.   37.  Defendant's likely defenses are and will be typical of and the same or  identical for each of the Class Members and will be based on the same legal and factual 0  theories. There are no valid unique defenses.   38.  The named Plaintiff will fairly and adequately represent and protect the  interests of the Class. The named Plaintiff has retained counsel that is experienced in  consumer litigation. The named Plaintiffs co-counsel is also experienced in consumer  cases including having been appointed as class counsel in a number of class actions  asserting claims under consumer protection laws.   39.  The named Plaintiff does not have any interests antagonistic to the  members of the Class.   40.  The Defendant acted on grounds that apply uniformly across the Class, so  that the statutory relief afforded pursuant to 15 U.S.C. § 1692k is appropriate to the  Class as a whole.   41.  Common questions predominate over any individual questions and a class  action is superior for the fair and efficient adjudication of this controversy.   42.  A class action will cause an orderly and expeditious administration of  Class members' claims, and economies of time, effort, and expenses will be fostered and  uniformity of decisions will be ensured.   43.  Plaintiffs claims are typical of the claims of the class members.   45.  Plaintiff incorporates the foregoing paragraphs by reference.   46.  Plaintiff is a "consumer" as defined by 15 U.S.C. § 1692a(3).   47.  The alleged debt at issue in this case is a "debt" within the meaning of 15  U.S.C. § 1692a(5).   48.  The Defendant is a "debt collector" within the meaning of 15 U.S.C. §  1692a(6). The Defendant regularly engages in collection efforts through the mails and  interstate commerce on behalf of third-parties.   49.  The Defendant violated 15 U.S.C. § 1692c(b) by communicating in  connection with the collection of the alleged debt with a third party. The communication  was not with the permission of Plaintiff, a court of competent jurisdiction, did not relate  to post-judgment enforcement and was not with a consumer reporting agency or other  person authorized by law to receive such communications.   50.  The Defendant's communication with third parties was not an attempt to  obtain location information for Plaintiff pursuant to 15 U.S.C. § 1692b.   51.  The Defendant violated 15 U.S.C. § 1692d(3) by publishing a list of  consumers who allegedly refuse to pay debts, to persons other than a credit reporting  agency or those meeting the requirements of 15 U.S.C. § 1681a(f) or 1681b(3).   53.  Plaintiff incorporates the foregoing paragraphs by reference.   54.  The Vermont Consumer Fraud Act, 9 V.S.A. § 2451 et seq. prohibits unfair  or deceptive trade practices.   55.  The Vermont Attorney General's regulations at Vt. Admin. Code 3-2-103:  CP 104 apply the Vermont Consumer Fraud Act to debt collection.   56.  Consumers are authorized to bring private actions by 9 V.S.A. § 2461(b).   57.  Plaintiff is a consumer within the meaning of 9 V.S.A. § 245ia(a) because  she purchased the timeshare to which the underlying debt related for private and  household purposes and not for use in connection with her trade or business.   59.  Defendant did not communicate the information to the third parties at  their request and the third parties had no legitimate business need for the information.   60.  The defendant did not communicate the information to the third parties in  order to obtain location information concerning Plaintiff.   61.  On information and belief, no judgment had been obtained against  Plaintiff.   62.  Defendant acted maliciously, with reckless or wanton disregard for the  rights of Plaintiff and Class because it knew that communicating the details of a person's  debt was a violation of the FDCP A and Vermont law, but nevertheless communicated  Plaintiff and Class members private information to third parties.   63.  The Plaintiff suffered an injury-in-fact as a result of Defendant's violation,  in that her right to privacy established under CP 104.03 was violated and her personal  information revealed to many other individuals.  Wherefore, Plaintiff and Class ask for the following relief from the court:  A. Certify the Class and appoint the Named Plaintiff as the class representative  and her lawyers as class counsel;  B. Award Plaintiff and the Class an am~mnt to be determined by the jury for  compensatory damages in an amount in excess of $75,000;  C. Award of costs, including reasonable attorney's fees.  D. Such other and further relief the nature of the Plaintiffs cause may require.  Fair Debt Collection Practices Act - Third Party Disclosure   Vermont Consumer Fraud Act  