Product: Credit reporting or other personal consumer reports

On XX/XX/XXXX XX/XX/XXXX, XXXX obtained a copy of her consumer report and discovered incomplete, inaccurate, false information furnished by the defendant XXXX. XXXX XXXX XXXX  XXXX XXXX. XXXXXXXX XXXX XXXXXXXX furnished one trade line, Account No. XXXX, XXXX XXXX : XXXX XXXX, in the amount of {$380.00}. 
On XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX XXXX contacted XXXX XXXX. XXXX XXXX XXXX  via certified mail by requesting that debt to be validated by the defendanXXXX XXXX XXXX XXXX XXXX providing a Complete payment history, the requirement of which has been established by XXXX XXXX XXXX, XXXX XXXX XXXX ; XXXX XXXX XXXX XXXX XXXXXXXX, date of last activity, Plaintiffs full, complete and correct social security number that may help to identify the Plaintiff as the correct person the defendant XXXX XXXX XXXX XXXX XXXX are trying to collect from, agreement that bears the signature of the alleged debtor wherein he/she agreed to pay the original creditor, the obligation between the defendant XXXX XXXX XXXX XXXX  and the Plaintiff that allows the defendant XXXX XXXX XXXX XXXX to collect on the alleged debt and any transactions between the defendant XXXX. XXXX XXXX XXXX that binds the Plaintiff to an agreement to pay the defendant XXXX. XXXXXXXX XXXX XXXX  any money that the defendant XXXX. XXXX XXXX XXXX claim the Plaintiff owe, proof of photo identification ( i.e., driver 's license, state identification card, or other government-issued identification cards ) that was presented to the original creditor at the time of incurring this debt, and letter of sale or assignment from the original creditor to XXXX. XXXXXXXX XXXX XXXX. ( Agreement with your client that grants you the authority to collect on this alleged debt. ) XXXX XXXX XXXXXXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX XXXX, XXXX ) XXXX XXXX XXXX XXXX XXXX sent Plaintiff a letter on XX/XX/XXXX refusing to fully validate the debt by stating that the request was Frivolous or irrelevant and in bad faith and to bring harassment. XXXX XXXX. XXXXXXXX XXXX XXXX also stated in received letter that they will no longer respond to any of Plaintiffs disputes or debt validation letters, which is a violation of the Fair Debt Collection Practices Act ( FDCPA ) Defendant XXXX XXXX XXXX XXXX failed to validate debt at the Plaintiff request- FDCPA violation, continued to report & communicate this disputed debt to the CRA- FCRA violation & FDCPA violation ( s ) 15 usc 1681b12, 15 usc 1692c . 
Plaintiff disputed the tradeline with Defendants Equifax and XXXX by sending written disputes on the following dates, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX as well as online disputes dated Plaintiff informed all defendants that the following information was inaccurate and needed to be investigated ; account status, last activity date, account opened date. The plaintiff requested to be provided proof of this alleged item, specifically the contract, note or other instrument bearing the Plaintiffs signature - Defendants Equifax and XXXX have violated 15 U.S.C. 1681i ( a ) ( 4 ) in that they failed to delete information that was inaccurate or could not be verified. 
- Defendants Equifax and XXXX have violated 15 U.S.C. 1681i ( a ) ( 5 ) because they ( i ) failed to reinvestigate the XXXX XXXX XXXX XXXX tradeline on Plaintiffs consumer report, ( ii ) failed to find it to be inaccurate, and ( iii ) failed to promptly notify XXXX XXXX XXXX XXXX  that the information was deleted from the Defendants file of Plaintiff - Defendants Equifax and XXXX have violated 15 U.S.C. 1681i ( 7 ) in that they failed to provide a written description of the procedure used to determine the accuracy and completeness of the disputed information. 
Defendants Equifax and XXXX have caused injury in fact, by causing, among other effects, mental and emotional distress, damage to credit reputation, and resulting in credit damages to Plaintiff. 
At all times alleged herein, Defendants Equifax and XXXX acted negligently and/or willfully. 

My potential legal claims pursuant to the FCRA include the following : ( 1 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( A ) failure to conduct a reasonable investigation on the alleged tradeline after receiving notice of the consumer dispute ; ( 2 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( B ) failing to review all relevant information forwarded to you by the consumer reporting agencies ; ( 3 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( C ) failure to report the accurate information to consumer reporting agencies and failing to report the results of the reinvestigation; ( 4 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( D ) failing to report accurate information to the consumer reporting agencies and continuing to report information that was false, inaccurate and unverifiable.

( 5 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( E ) failing to have a procedure in your system with the consumer reporting agencies to ( i ) modify the inaccurate information in your system, ( ii ) delete the inaccurate or unverifiable, erroneous information, or ( iii ) block the re-reporting of inaccurate or unverifiable information.