[brief] E.  The Persels case involves a materially different statute and provides no assistance to the Court in examining this matter.  The [...]’s reliance on a Connecticut case of Persels & Assocs., LLC v.  Banking Commissioner, 122 A.3d 592 (Conn. 2015), is misplaced.  Apart from being non-precedential, R. 1:36-3, it is distinguishable because Persels considered a statute that is materially different from the DACCA.  In Persels, the Connecticut Supreme Court invalidated a certain provision of the Connecticut Debt Negotiations statute, which exempted from its application “any attorney admitted to the practice of law in this state who engages or offers to engage in debt negotiation as an ancillary matter to such its attorney's representation of a client. ”  Conn. Gen. Stat. Ann. § 36a-671(c).  Specifically, the Connecticut Supreme Court held that this provision unconstitutionally regulates the practice of law.  Id. at 594.  However, the Connecticut statute materially differed from the DACCA in the following regards.  First, the Connecticut statute contemplated licensure of, supervision of, and enforcement actions against individuals, which could include attorneys, by the Connecticut Commissioner of the Department of Banking.  See Conn. Gen. Stat. Ann. § 36a-671(b) (“No person shall engage or offer to engage in debt negotiation in [Connecticut] unless such person has first obtained a license for its main office and for each branch office where such business is conducted”); § 36a-671(c) (authorizing the Commissioner of the Department of Banking to issue a license); § 36a-671a (authorizing the Commissioner of the Department of Banking to suspend or revoke a license, to review fees, to order a licensee to remove any individual from employment, and to order cease and desist); and § 36a-671f (outlining prohibited practices).  As explained above, the DACCA does not license, regulate nor supervise individuals, let alone attorneys.  Under the DACCA, only nonprofit entities can obtain a license and thus be subject to the Department’s supervision.  See N.J.S.A. 17:16G-2(a) and -2(b).  Second, the Connecticut statute is triggered immediately when an attorney negotiates or arranges a debt on behalf of a single client, regardless of the scope of their practice.  In contrast, the DACCA provides an exemption for attorneys who are not principally engaged in debt adjustment, meaning their involvement in debt adjustment activities is evaluated in the context of their overall practice.  Compare Conn. Gen. Stat. Ann. § 36a-671(b) (prohibiting any debt negotiation activity without a license) with N.J.S.A. 17:16G-1(c)(2) (exempting attorneys whose principal activity is not debt adjustment, thereby allowing an assessment of the attorney’s overall practice).  Finally, the scope of activities regulated by the Connecticut statute was significantly broader than that of the DACCA.  Under the DACCA, a person must act with the specific purpose of “settling, compounding, or otherwise altering the terms of payment of any debts of the debtor” for the statute to apply.  N.J.S.A. 17:16G-1(c)(1).  In contrast, the Connecticut statute encompasses a far wider range of conduct, applying even when a person merely assists a debtor in negotiating or attempting to negotiate with creditors.  Conn. Gen. Stat. Ann. § 36a-671(a).  Given these differences, the statute at issue in Persels was both broader in scope and distinct in its application compared to the DACCA.  Therefore, Persels is not instructive on the issue in the present case.