 Plaintiff, repeats and re-alleges Paragraphs 1-41 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 it used  a third-party vendor to mail the October 24, 2020 collection letter to Plaintiff.    Defendant violated Section 1692c(b) when it used a third-party vendor to mail the  October 24, 2020 collection letter to Plaintiff because by using a third-party vendor to mail out the  letters, Defendant disclosed Plaintiff’s personal contact information and information identifying  the Subject Debt to Defendant’s letter vendor.    ARS’s transmittal of Plaintiff’s personal information, Plaintiff’s purported status as  a debtor relative to a debt allegedly owed to JPMorgan Chase Bank, N.A., and the amount of the  9  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 October 24, 2020 collection letter to Plaintiff violated Section 1692c(b).    ARS’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.    ARS’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.    ARS’s transmittal of Plaintiff’s personal information and information identifying  the Subject Debt to its letter vendor was not done in an attempt to comply with Section 1692b.    ARS’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, ARS’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.   10    Accordingly, Plaintiff has standing to sue ARS 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 class encompasses:   (a) all consumers with addresses in the State of Texas;   (b) where Defendant utilized form collection letters for the purposes of  attempting to collect to a consumer based debt allegedly owed to to  JPMorgan Chase Bank, N.A;   (c) where Defendant used a third-party letter vendor to transmit the  collection letters; and  (d) Defendant’s use of a third-party letter vendor resulted in Defendant  sending the demographic information of the subject consumers as well as  their status as alleged debtors to the letter vendor in violation of Section  1692c(b) of the FDCPA.     Defendant is not entitled to invoke arbitration, because upon information and belief,  the Subject Debt is not governed by an arbitration clause.  WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter judgment in  her favor and against Defendant ARS 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.  11  Class Action Violations of § 1692c(b) of the FDCPA Resulting From Defendant’s   Sharing of Plaintiff’s Personal Information and her Status as a Debtor   