[brief] Based on the Standard of Review (Point I, below), the facts are derived from the Complaint’s factual allegations, documents attached to or relied on in the Complaint, and matters of public record.  Plaintiff is a natural person.  In late May 2020, Plaintiff received a letter from Defendant dated May 23, 2020.  The letter attempts to collect money on an allegedly defaulted payment obligation with respect to a balance on a Mastercard credit card account.  The collection letter (Pa9-Pa10) proposed three payment options: - “Offer #1 – Single payment and the largest savings. ”  - “Offer #2 – Payment plan with savings. ”  - “Offer #3 – Pay your account in full with monthly payments”  Later on, the collection letter disclosed, “Because of the age of you debt, we ([...]) cannot sue you for it and we will not report it to any credit reporting agency. ”  Then, the letter explained that the debt could be renewed and the time within which to sue could be restarted if Plaintiff were to make a payment or “a written promise to pay. ”  Thus, by agreeing to Offer #1, Offer #2, or Offer #3, Plaintiff might convert a time-barred debt into either one on which he could be sued or create a new contract (such as an accord-and-satisfaction) upon which he could be sued.  But by doing nothing, Plaintiff would realize the greatest savings of 100% and accepting any of the three Offers actually is a loss.  But the least sophisticated consumer would not understand the undisclosed comparison to paying nothing.  The Complaint alleges that Defendant’s collection letter “included convoluted language which could mislead the least sophisticated consumer about the effect of a payment or an agreement to pay on the statute of limitations. ”  Pa3 at ¶12.  Therefore, the letter is false, deceptive, and misleading to the least sophisticated consumer in violation of the FDCPA.  To create the letter, Defendant deprived Plaintiff of the FDCPA’s protection of his individual privacy.  As explained below in the Legal Arguments, the FDCPA prohibits a debt collector from communicating with “any person” in connection with the collection of a debt except for a narrowly defined group of people and a few specific circumstances—none of which apply to Defendant’s communication.  The FDCPA does not distinguish among the universe of people (excluding those expressly excepted); instead, the FDCPA flatly prohibits all such communications.  Here, Defendant conveyed private information about Plaintiff and the debt he allegedly owed to a third-party.  The FDCPA proscribes that conduct.  Nothing in the statute carves out any exception for communications with a third party engaged to merge that information into a letter template to create, print, and mail Defendant’s collection letter.  Indeed, every federal court, including a published U.S. Court of Appeals decision and two published U.S. District Court decisions, conclude that alleging a debt collector conveyed such information to a mail vendor states a claim for relief for violation of § 1692c(b).  The motion court concluded Plaintiff lacks standing but nevertheless proceeded to also conclude that the Complaint failed to state a claim for violation of the FDCPA based on (i) the collection letter’s convoluted language as to the time-barred nature of the debt and restarting the statute of limitations or (ii) Defendant’s communication with a third-party.