10.  Plaintiff's alleged debt was primarily for personal, family or household purposes  and is therefore a “debt” as defined by 15 U.S.C. § 1692a(5).   11.  Sometime after the incurrence of the debt, but before the initiation of this action,  Plaintiff is alleged to have fallen behind on payments allegedly owed on the alleged debt.    12.  At a time known only to Defendant, Plaintiff's alleged debt was assigned or  otherwise transferred to Defendant for collection.    13.  In its efforts to collect the alleged debt, Defendant contacted Plaintiff by written  correspondence. (“Exhibit 1.”)    14.  Defendant's written correspondence to Plaintiff is a “communication” as defined  by 15 U.S.C. § 1692a(2).   16.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     17.  15 U.S.C. § 1692f provides a debt collector may not use unfair or unconscionable  means to collect or attempt to collect any debt.   18.  15 U.S.C. § 1692f(8) limits the language and symbols that a debt collector may  place on envelopes it sends to consumers.     19.  15 U.S.C. § 1692f(8) prohibits a debt collector from using any language or  symbols on the envelope, other than the debt collector’s address, when communicating with a  consumer by mail, except that a debt collector may place its business name on the envelope if  such name does not indicate that the debt collector is in the debt collection business.   20.  15 U.S.C. § 1692f(8)’s prohibition applies to language and symbols both on the  envelope, and language and symbols visible through any glassine window of the envelope. See,  Douglass v. Convergent Outsourcing,  765 F.3d 299  (3rd Cir 2014).   21.  Defendant assigned Plaintiff account number XXXX4648.   22.  Plaintiff’s original account number is XXXX8192.   23.  Visible through the glassine window of the envelope sent to Plaintiff was a Quick  Response Code, or QR code, which when scanned reveals Plaintiff’s account number and  account information.      24.  The QR code visible through the glassine window can be easily scanned by  anyone with a smartphone, as QR code scanning applications are easily accessible to the public  free of charge.   25.  Defendant disclosed Plaintiff’s account information in its mailing to Plaintiff by  placing such QR code on the envelope, or making such visible through the glassine window of  the envelope.    26.  Defendant used language other than Defendant’s address and business name, on  the envelope it sent to Plaintiff.    27.  Defendant has violated § 1692f by using language other than Defendant’s address  and business name, on the envelope it sent to Plaintiff.   29.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     30.  Defendant owed a duty to Plaintiff to effect its collection of Plaintiff's alleged  debt with reasonable care.   31.  Defendant's conduct as described herein shows a lack of exercise of reasonable  care in Defendant's collection of the alleged debt.   32.  Defendant breached its duty to collect Plaintiff's alleged debt with reasonable  care.   33.  Defendant's conduct was committed by Defendant in the conduct of a business,  trade or commerce or the furnishing of a service in New York State and constitutes a violation of  NY GBL § 349(a).   34.  Defendant's conduct was consumer-orientated in that the letter was sent in an  effort to collect an alleged consumer debt.   35.  Defendant's conduct has a broader impact on consumers at large as, upon  information and belief, Defendant has sent the subject form letter to hundreds of consumers.     36.  Plaintiff is a reasonable consumer.   37.  Defendant's conduct would mislead a reasonable consumer.     38.  Defendant engaged in a material deceptive act or practice as described herein.   39.  Defendant's conduct caused plaintiff to suffer injury.    40.  Defendant violated NY GBL § 349(a) and is liable to Plaintiff pursuant to NY  GBL § 349(h).  Violation of New York General Business Law § 349   Violation of 15 U.S.C. § 1692f  Disclosure of Plaintiff's Account Information  