[brief] “[C]ollecting or enforcing a loan, whether by the lender or its assignee, constitutes the ‘subsequent performance’ of a loan, an activity falling within the coverage of the CFA. ”  Gonzalez v. Wilshire Credit Corp., 207 N.J. 557, 577-78 (2011).  The holding in Gonzalez is as clear as it is broad.  However, Defendants attempt to improperly narrow the holding in Gonzalez by relying on Chulsky v. Hudson Law Offices, P.C., 777 F. Supp. 2d 823 (D.N.J. 2011) and DepoLink Court Reporting & Litig. Support Servs. v. Rochman, 430 N.J. Super. 325 (App. Div. 2013).  However, as explained in [...]’s opening Brief, Chulsky was a case in the United States District Court for the District of New Jersey decided before Gonzalez.  For those reasons alone, Chulsky cannot control here or overrule Gonzalez.  Moreover, the Chulsky court asked a question that was explicitly answered by the New Jersey Supreme Court in Gonzalez, i.e., whether the “[CFA] applies, in like manner, to assignees or debt buyers who purchase and attempt to collect upon defaulted debt. ”  See Chulsky, 777 F. Supp. 2d at 838.  Gonzalez responded by explicitly determining that “collecting or enforcing a loan, whether by the lender or its assignee, constitutes the ‘subsequent performance’ of a loan, an activity falling within the coverage of the CFA. ”  Gonzalez, 207 N.J. at 577-78.  With respect to the holding in DepoLink, as explained in [...]’s opening Brief, the violations of the CFA in DepoLink were committed by the merchant transcription agency, prior to the account being referred to a collection agency.  DepoLink did not analyze subsequent performance under the CFA—which Gonzalez says encompasses collection activity—because the CFA violation occurred during the sale of the merchandise.  Indeed, the only time DepoLink mentions subsequent performance is in quoting N.J.S.A. 56:8-2.  See DepoLink, 430 N.J. Super. at 337.  Here, the CFA violation was not committed by the original creditor when the credit was sold; it was committed by Defendants after [...]’s alleged debt was charged off.  Despite being legally disallowed from possessing [...]’s account, Defendants continued to assess interest on the void debt, then attempted to collect the same.  Thus, the facts of the instant action are more aligned with Gonzalez than DepoLink.  Additionally, [...] and [...] argue that they are not beholden to the requirements of the NJCFLA because “[n]either [...] nor [...] are incorporated or based in New Jersey. ”  [...]’s Br. 13.  However, [...] and [...] neglect the fact that they purchased an account that originated in New Jersey, ostensibly belonging to a New Jersey consumer.  By [...]’s and [...]’s rationale, they could avail themselves to the laws of New Jersey however they want and commit any infractions they see fit as long as they do not register to conduct business in the State of New Jersey.  Here, Defendants violated the CFA by misrepresenting that they were legally allowed to possess and enforce [...]’s alleged debt, when in fact they lacked the licensure necessary to even possess [...]’s account.  By attempting to possess, sell, and enforce a void debt, Defendants engaged in fraud in connection with the subsequent performance of the sale of merchandise.  Thus, the October 20, 2023 Orders granting Defendants’ Motion to Dismiss and denying [...]’s Cross Motion to Vacate, Transfer, and Consolidate should be reversed.