"[W]hether a communication is 'in connection with the collection of [a] debt' is a question of fact to be determined by reference to an objective standard. . . . [W]e must view the communication objectively, asking whether [the plaintiff] has plausibly alleged that a consumer receiving the communication could reasonably interpret it as being sent 'in connection with the collection of [a] debt,' rather than inquiring into the sender's subjective purpose. Such an inquiry is consistent with the FDCPA's goal of protecting consumers: if a consumer receiving a letter could reasonably understand it to be a communication in connection with the collection of a debt, then the consumer is entitled to the protections Congress has mandated{**76 Misc 3d at 734} for such communications." (Hart, 797 F3d at 225 [citations omitted].)
The Second Circuit observed that whereas two other circuit courts[FN4] had held that such communications "must attempt to induce the borrower to pay, not just convey information about the debt," a local district court had "recently construed the phrase far more flexibly when it rejected the information/inducement dichotomy and reasoned that 'in connection with' is 'synonymous with the phrases "related to," "associated with," and "with respect to," ' and does not necessitate any inducement element." (Hart, 797 F3d at 225-226, quoting Tocco v Real Time Resolutions, Inc., 48 F Supp 3d 535, 540 [SD NY 2014].) The Second Circuit did not resolve that discrepancy, holding on the facts of the case before it only that "an attempt to collect a debt . . . qualifies as a communication 'in connection with the collection of any debt.' " (Hart at 226; see also Schwebel v Resurgent Capital [*8]Servs., L.P., 2020 WL 5663382, *5, 2020 US Dist LEXIS 174738, *10 [SD NY, Sept.