 Plaintiff, repeats and re-alleges Paragraphs 1-38 as though fully set forth herein.    Section 1692c(b) with certain inapplicable exceptions, prohibits debt collectors  from communicating consumers’ personal information to third parties “in connection with the  collection of any debt.”     As discussed above and below, Defendant violated Section 1692c(b) when they  disclosed Plaintiff’s personal contact information and information identifying the Subject Debt to  CBHV’s Letter Vendor.    CBHV’s transmittal of Plaintiff’s personal information, Plaintiff’s purported status  as a debtor relative to a debt allegedly owed to Midnight Velvet, and the amount of the Subject  Debt to Defendant’s letter vendor constitutes a "communication" within the meaning of Section  1692a(2) which defines “communication” as "the conveying of information regarding a debt  directly or indirectly to any person through any medium." 15 U.S.C. § 1692a(2).    Defendant’s use of a third-party letter vendor to merge Plaintiff’s demographic data  and status as a debtor into Defendant’s form collection letters for the purpose of printing and  mailing the May 14, 2020 collection letter to Plaintiff violated Section 1692c(b).    CBHV’s disclosure of Plaintiff’s personal information and her status as a purported  debtor posed a material risk of harm to the privacy interests protected by the FDCPA.    CBHV’s disclosures of Plaintiff’s personal information and status as a purported  debtor to its third-party letter vendor violated Plaintiff’s rights privacy that was recognized by  Congress when it enacted the FDCPA.    CBHV’s disclosure to its Letter Vendor of Plaintiff’s personal information and her  purported status as a person owing the Subject Debt violated Section 1692c(b)’s prohibition on  disclosure of debtor information to third-parties    Section 1692c(b) bears a close relationship to a privacy invasion that American  courts have long recognized as cognizable.      Congress's judgment indicates that violations of Section 1692c(b) constitute a  concrete injury.    As set forth above, CBHV’s disclosures to its third-party letter vendor (of Plaintiff’s  personal information and status as a purported debtor) caused Plaintiff to suffer from  embarrassment, aggravation and emotional distress.     Accordingly, Plaintiff has standing to sue CBHV for its improper and unlawful  disclosure of Plaintiff’s personal information and status as a debtor to third-party letter vendors.    The claims asserted in this Count satisfy the elements of FRCP 23(a)(1)-(4) and  FRCP 23(b)(3).    The proposed Midnight Velvet class encompasses:  (a) all consumers with addresses in the State of California;   (b) who originally owed debts to Midnight Velvet;   (c) where Defendant caused form collection letters to be mailed to be sent  for the purposes of attempting to collect to a consumer based debt allegedly  owed to Midnight Velvet; and   (d) Defendant used a letter vendor to transmit the letters which resulted in  the vendor being sent the demographic information of the consumers as well  as their status as alleged debtors.    The above classes are limited to one year prior to the filing of the Complaint until such time as Defendant ceases the offending conduct.  WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter judgment in  her favor and against Defendant CBHV as follows:  a. Declaring that the practices complained of herein are unlawful; b. Awarding Plaintiff and class members statutory damages of $1,000.00 as provided under 15 U.S.C. §§ 1692k(a)(2)(A) and 1692k(a)(2)(B); c. Awarding Plaintiff actual damages as provided by 15 U.S.C. §1692k(a)(1)); d. Awarding Plaintiff costs and reasonable attorney’s fees as provided under 15 U.S.C. §1692k(a)(3); and e. Awarding any other relief as this Honorable Court deems just and appropriate. Plaintiff, repeats and re-alleges Paragraphs 1-38 as though fully set forth herein.  California Civil Code § 1788.17 provides: Notwithstanding any other provision of this title, every debt collector collecting or attempting to collect a consumer debt shall comply with the provisions of Section 1692b to 1692j, inclusive, of, and shall be subject to the remedies in Section 1692k of, Title 15 of the United States Code.  As alleged, above, CBHV violated 15 U.S.C. § 1692c(b) of the FDCPA.  In violating Section 1692c(b), Defendant violated Cal. Civ. Code § 1788.17.  Individual Based Violations of the Rosenthal Fair Debt Collection Practices Act   (Cal. Civ. Code § 1788 et seq.)  