102.  Plaintiff brings this action individually and as a class action on behalf of all  consumers similarly situated in Nassau County, New York.  103.  Plaintiff seeks to certify a class of:  i. All consumers where Arrowood 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.  104.  This action seeks a finding that Arrowood’s conduct violates the FDCPA and asks  that the Court award damages as authorized by 15 U.S.C. § 1692k.  11  105.  The Class consists of more than thirty-five persons.  106.  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.  107.  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.  Arrowood  has acted in a manner applicable to the Class as a whole such that declaratory relief is warranted.  108.  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 Arrowood’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.  15.  Arrowood alleges Plaintiff owes it $31,858.04 (“the alleged Debt”).    16.  Plaintiff did not owe $31,858.04 (“the Claimed Amount”) to Arrowood.   17.  Plaintiff did not owe money to Arrowood.   18.  Plaintiff was never indebted to Arrowood.   19.  Plaintiff did not owe the alleged Debt to Arrowood.   20.  Arrowood never offered to extend credit to Plaintiff.   21.  Arrowood never extended credit to Plaintiff.     22.  Plaintiff was never involved in any transaction with Arrowood.   23.  Plaintiff never entered into any contract with Arrowood.   24.  Plaintiff never did any business with Arrowood.   25.  Plaintiff was never advised by anyone that the alleged Debt was sold to Arrowood.   26.  Plaintiff was never advised by anyone that the alleged Debt was assigned to  Arrowood.   27.  Plaintiff was never advised by anyone that the alleged Debt was transferred  Arrowood.   28.  Plaintiff was never advised by anyone that the alleged Debt was acquired by  Arrowood.   29.  Plaintiff was never advised by Arrowood that the alleged Debt was sold to it.     30.  Plaintiff was never advised by Arrowood that the alleged Debt was assigned to it.     31.  Plaintiff was never advised by Arrowood that the alleged Debt was transferred to  it.    4   32.  Plaintiff was never advised by Arrowood that the alleged Debt was acquired by it.     33.  Arrowood is a stranger to Plaintiff.   34.  Upon information and belief, Arrowood does not possess competent proof that any  entity assigned to it all of that entity’s interest in the alleged Debt.   35.  Upon information and belief, Arrowood does not possess competent proof that any  entity assigned to it the right to any proceeds from the alleged Debt.   36.  Upon information and belief, Arrowood does not possess competent business  records concerning the alleged Debt from any entity that owned the alleged Debt.   37.  Upon information and belief, Arrowood does not possess personal knowledge of  the facts set forth in any business records concerning the alleged Debt received from any entity  that owned the alleged Debt.   38.  Upon information and belief, Arrowood does not possess any credit agreement  between Plaintiff and any entity that owned the alleged Debt.   39.  Upon information and belief, Arrowood does not possess any competent proof that  Plaintiff agreed to pay the alleged Debt.   40.  Upon information and belief, Arrowood does not possess any competent proof that  Plaintiff is obligated to pay the alleged Debt.   41.  Upon information and belief, Arrowood does not possess any competent proof that  Plaintiff owed the Claimed Amount at the time Arrowood ostensibly acquired the alleged Debt.   42.  Upon information and belief, Arrowood does not possess any competent proof that  the Claimed Amount was accurate at the time Arrowood ostensibly acquired the alleged Debt.   43.  Upon information and belief, Arrowood  holds no legal right, title or interest in any  debt Plaintiff allegedly owed.  5   44.  The alleged Debt does not arise from any business enterprise of Plaintiff.   45.  The alleged Debt is a “debt” as that term is defined by 15 U.S.C. § 1692a(5).   46.  At an exact time known only to Arrowood, Arrowood decided to hire Rubin &  Rothman, LLC (“Rubin”) to attempt to collect the alleged Debt on Arrowood’s behalf.   47.  As part of its utilization of Rubin, Arrowood conveyed information regarding the  alleged Debt to Rubin.   48.  The information conveyed by Arrowood to Rubin 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.   49.  Arrowood’s conveyance of the information regarding the alleged Debt to Rubin is  a “communication” as that term is defined by 15 U.S.C. § 1692a(2).   50.  At the time the alleged Debt was assigned or otherwise transferred to Rubin for  collection, the alleged Debt was in default.   51.  In its efforts to collect the alleged Debt, Rubin decided to contact Plaintiff by  written correspondence.   52.  At all times relevant herein, Rubin was acting as a “debt collector” as that term is  defined by the FDCPA.    53.  That correspondence, dated April 5, 2021, was received, and read by Plaintiff.  (A  true and accurate copy of that correspondence (the “Letter”) is annexed hereto as “Exhibit 1.”)   54.  The Letter, which conveyed information about the alleged Debt, is a  “communication” as that term is defined by 15 U.S.C. § 1692a(2).   55.  The Letter was the initial written communication Plaintiff received from Arrowood  concerning the alleged Debt.  6  56.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     57.  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.”   58.  Rubin does not fall within any of the exceptions provided for in 15 U.S.C. §  1692c(b).   59.  Plaintiff never consented to Arrowood’s communication with Rubin concerning the  alleged Debt.   60.  Plaintiff never consented to Arrowood’s communication with Rubin concerning  Plaintiff’s personal and/or confidential information.   61.  Plaintiff never consented to Arrowood’s communication with anyone concerning  the alleged Debt or concerning Plaintiff’s personal and/or confidential information.   62.  Upon information and belief, Arrowood has utilized Rubin for these purposes  thousands of times.   63.  Arrowood utilizes Rubin in this regard for the sole purpose of maximizing its  profits.   64.  Arrowood utilizes Rubin without regard to the propriety and privacy of the  information which it discloses to Rubin.   65.  Arrowood utilizes Rubin with reckless disregard for the harm to Plaintiff and other  consumers that could result from Arrowood’s unauthorized disclosure of such private and sensitive  information.  7   66.  Arrowood violated 15 U.S.C. § 1692c(b) when it disclosed information about  Plaintiff’s alleged Debt to Rubin.   67.  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.     68.  The unauthorized disclosure of a consumer’s private and sensitive information is  both unfair and unconscionable.   69.  Arrowood disclosed Plaintiff’s private and sensitive information to Rubin.   70.  Arrowood violated 15 U.S.C. § 1692c(b) when it disclosed information about  Plaintiff’s alleged Debt to Rubin.   71.  For the foregoing reasons, Arrowood violated 15 U.S.C. §§ 1692c(b) and 1692f  and is liable to Plaintiff therefor.  72.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     73.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.   74.  As relevant here, 15 U.S.C. § 1692g(a)(1) requires the written notice provide a  statement of the amount of the debt.   75.  To comply with 15 U.S.C. § 1692g(a)(1), the statement of the amount of the debt  must accurately set forth the actual amount of the debt.   76.  A statement of the amount of the debt, when the debt is not owed at all by the  consumer, violates 15 U.S.C. § 1692g(a)(1).  8   77.  As set forth in paragraphs 15 through 43 of this Complaint, Plaintiff did not owe  the Claimed Amount.   78.  As such, Arrowood did not accurately set forth the actual amount of the alleged  debt as required by 15 U.S.C. § 1692g(a)(1).    79.  In sum, Arrowood’ statement of the amount of the alleged Debt, when Plaintiff did  not owe that amount, violates 15 U.S.C. § 1692g(a)(1).   80.  As also relevant here, 15 U.S.C. § 1692g(a)(2) requires the written notice provide  a statement of the name of the creditor to whom the debt is owed.   81.  To comply with 15 U.S.C. § 1692g(a)(2), the statement of the name of the creditor  to whom the debt is owed must accurately set forth the name of the entity that actually owns the  debt.   82.  A statement of the name of the creditor to whom the debt is owed, when the  consumer does not owe money to the stated entity, violates 15 U.S.C. § 1692g(a)(2).   83.  As set forth in paragraphs 15 through 43 of this Complaint, Plaintiff did not owe  money to Arrowood.     84.  As such, Arrowood did not accurately set forth the name of the entity that actually  owns the debt as required by 15 U.S.C. § 1692g(a)(2).    85.  In sum, Arrowood’s statement that Arrowood was the name of the creditor to whom  the alleged debt was owed, when Plaintiff did not owe any money to Arrowood, violates 15 U.S.C.  § 1692g(a)(2).   86.  For the foregoing reasons, Arrowood violated 15 U.S.C. §§ 1692g, 1692g(a)(1) and  1692g(a)(2) and is liable to Plaintiff therefor.  9  87.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.    88.  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.   89.  15 U.S.C. § 1692e(2)(A) prohibits the false representation of the character, amount,  or legal status of any debt.   90.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     91.  An allegation by a debt collector that a consumer owes a debt to a certain entity  when the consumer does not owe a debt to that entity is a violation of 15 U.S.C. §§ 1692e,  1692e(2)(A) and 1692e(10).   92.  An allegation by a debt collector that a consumer owes a certain amount of money  when the consumer does not that amount is a violation of 15 U.S.C. §§ 1692e, 1692e(2)(A) and  1692e(10).   93.  As set forth in paragraphs 14 through 43 of this Complaint, Plaintiff did not owe  the Claimed Amount.   94.  As set forth in paragraphs 14 through 43 of this Complaint, Plaintiff did not owe  money to Arrowood.     95.  As such, Arrowood’s allegation that Plaintiff owed the Claimed Amount 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.  10   96.  Arrowood’s allegation that Plaintiff owed money to Arrowood 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.   97.  Arrowood’s allegation that Plaintiff owed the Claimed Amount is a false  representation of the character, amount, and/or legal status of the alleged Debt in violation of 15  U.S.C. § 1692e(2)(A).   98.  Arrowood’s allegation that Plaintiff owed money to Arrowood is a false  representation of the character, amount, and/or legal status of the alleged Debt in violation of 15  U.S.C. § 1692e(2)(A).   99.  Arrowood’s allegation that Plaintiff owed the Claimed Amount is a false  representation made in an attempt to collect the alleged Debt in violation of 15 U.S.C. § 1692e(10).  100.  Arrowood’s allegation that Plaintiff owed money to Arrowood is a false  representation made in an attempt to collect the alleged Debt in violation of 15 U.S.C. § 1692e(10).  101.  For the foregoing reasons, Arrowood violated 15 U.S.C. §§ 1692e, 1692e(2)(A)  and 1692e(10) and are liable to Plaintiff therefor.  Violation of 15 U.S.C. §§ 1692e, 1692e(2)(A) and 1692e(10)   Violation of 15 U.S.C. §§ 1692g, 1692g(a)(1), 1692g(a)(2)   Violation of 15 U.S.C. § 1692c(b) and § 1692f   