13. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered “1” through “12” herein with the same force and effect as if the same were set  forth at length herein.   14. Some time prior to March 5, 2015, an obligation was allegedly incurred to AT&T  Mobility. (“AT&T”)   15. The AT&T obligation arose out of a transaction in which money, property, insurance or  services, which are the subject of the transaction, are primarily for personal, family or  household purposes.   16. The alleged AT&T obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   17. Defendant contends that the AT&T debt is past due.   18. Defendant collects and attempts to collect debts incurred or alleged to have been incurred  for personal, family or household purposes on behalf of creditors using the United States  Postal Services, telephone and Internet.   19. Some point prior to March 5, 2015, the AT&T debt was sold, consigned, or otherwise  transferred to US Asset Management Inc. (“UAM”) for collections.   20. UAM is a “creditor as defined by 15 U.S.C.§ 1692a(4).   22. On or about March 5, 2015, the Defendant caused to be delivered to the Plaintiff a letter  in an attempt to collect the alleged UAM debt. See Exhibit A.   23. The March 5, 2015 letter was sent or caused to be sent by persons employed by  Defendant as a “debt collector” as defined by 15 U.S.C. §1692a(6).   24. The March 5, 2015 letter is a “communication” as defined by 15 U.S.C. §1692a(2).   25. The March 5, 2015 letter was sent in an envelope that contained a glassine window with a  visible QR code.   26. When scanned, the QR code revealed Plaintiff’s account number with EOS.   27. The invoice/account number constitutes personal identifying information.    28. The invoice/account number is a piece of information that can identify the Plaintiff as a  debtor, in violation of the FDCPA.   29. The ID number is not meaningless – it is a piece of information capable of identifying  [the consumer] as a debtor, and its disclosure has the potential to cause harm to a  consumer that the FDCPA was enacted to address. Douglass v. Convergent Outsourcing,  765 F. 3d 299 (Third Cir. 2014).   30. Defendant’s actions as described herein are part of a pattern and practice used to collect  consumer debts.   31. Defendant could have taken the steps necessary to bring its actions within compliance  with the FDCPA, but neglected to do so and failed to adequately review its actions to  ensure compliance with the law.   33. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered “1” through “32” herein with the same force and effect as if the same were set  forth at length herein.   34. Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. §  1692f.   35. Pursuant to 15 U.S.C. §1692f(8), a debt collector is prohibited from using any language  or symbol, other than the debt collector’s address, on any envelope when communicating  with the consumer by use of mails.   36. The Defendant violated said section by putting the Plaintiff’s ID number visible on the  March 5, 2015 letter.   37. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's conduct  violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692f et seq.  