In Centurion Capital Corp. v. Druce (14 Misc 3d 564, 828 NYS2d 851 [Civ Ct, NY County 2006]), the plaintiff commenced an action against the defendant to recover on an alleged credit card agreement. Plaintiff was a debt collection agency that had purchased defendant's credit card debt. Defendant counterclaimed that plaintiff had engaged in deceptive business practices and sought costs and attorney's fees. Plaintiff moved for summary judgment and to dismiss defendant's counterclaims. Defendant cross-moved to dismiss the complaint on the grounds that plaintiff was an unlicenced debt collection agency. The issue was whether plaintiff was an unlicensed debt collection agency under the Administrative Code of the City of New York. The court found that plaintiff was a debt collection agency required to be licensed, and as such, must satisfy CPLR 3015. Since plaintiff did not comply with the CPLR, the complaint was dismissed.