Product: Credit reporting or other personal consumer reports

COMPLAINT XXXX. Introduction Plaintiff, XXXX XXXX XXXX, by and through undersigned counsel, brings this action against Defendant Apple Card/GS Bank USA for violations of the Fair Credit Reporting Act, 15 U.S.C. 1681, et seq. Plaintiff seeks damages and equitable relief due to Defendants failure to reasonably investigate Plaintiff 's dispute regarding inaccurate information on Plaintiffs consumer report, as required by law.

2. Jurisdiction and Venue This Court has jurisdiction over this action under 15 U.S.C. 1681p and 28 U.S.C. 1331 as it arises under the Fair Credit Reporting Act.

Venue is proper in this judicial district under 28 U.S.C. 1391 ( b ) as Plaintiff resides within this district and the acts or omissions giving rise to this Complaint occurred here. 
XXXX. Parties Plaintiff XXXX XXXX XXXX ( XXXX : XX/XX/XXXX ) is a natural person residing at XXXX XXXX XXXX XXXX, XXXX, AZ XXXX. 
Defendant Apple Card/GS Bank USA XXXX hereinafter Defendant or GS Bank ) is a financial institution and furnisher of information under 15 U.S.C. 1681s-2, authorized to conduct business in the state of Arizona.

4. Factual Background Plaintiff applied for and was approved for an Apple Card through Defendant GS Bank. 
As of XX/XX/XXXX, XXXX noticed inaccurate information on his credit report concerning his Apple Card account, including but not limited to incorrect payment history, status of delinquency, and the outstanding balance reported as a charge-off. 
Specifically, XXXX reported : An inaccurate balance of {$3000.00}, which represents 202 % of the credit limit ( {$1500.00} ), suggesting an error in how the balance is calculated or reported. 
A payment history marked with multiple delinquent entries, despite Plaintiffs efforts to address any arrears. 
The account status as Charge-Off, although Plaintiff has disputed this characterization.

Plaintiff promptly disputed these inaccuracies with each major credit reporting agency ( XXXX, XXXX, and XXXX ) and requested that Defendant XXXX Bank correct the reported information in accordance with FCRA requirements. 
XXXX. Defendant 's Failure to Conduct a Reasonable Investigation Upon notification from the credit reporting agencies, Defendant GS Bank was legally obligated under 15 U.S.C. 1681s-2 ( b ) to conduct a reasonable investigation into Plaintiffs dispute and to verify, modify, or delete inaccurate information.

Defendant GS Bank failed to perform a reasonable investigation into Plaintiffs dispute as required by FCRA, as evidenced by the continued presence of inaccuracies on Plaintiffs credit report.

Defendants failure to correct the inaccurate information following Plaintiffs dispute constitutes a violation of the FCRA, as its investigation was cursory and did not fulfill the statutory mandate of reasonableness, as outlined in XXXX v. XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ). 
XXXX. Inaccurate Reporting by Credit Reporting Agencies Each credit reporting agency continues to report the disputed Apple Card account inaccurately, reflecting : An erroneous Charge-Off status, Delinquent payment history that is inconsistent with the actual payment activity, A disproportionately high outstanding balance.

Plaintiffs credit report, as a result, does not accurately reflect Plaintiffs creditworthiness or financial responsibility, causing substantial harm to Plaintiffs reputation and financial opportunities. 
XXXX. Defendants Willful and/or Negligent Non-Compliance Defendants failure to conduct a reasonable investigation and failure to correct the disputed information upon receiving notice of Plaintiffs dispute, despite statutory obligations to do so, constitute a reckless disregard of its duties under FCRA. 
Defendants actions were willful, entitling Plaintiff to statutory and punitive damages under XXXX U.S.C. 1681n. Alternatively, Defendants actions were negligent, entitling Plaintiff to actual damages under 15 U.S.C. 1681o.

8. Claims for Relief Count I Violation of the Fair Credit Reporting Act ( 15 U.S.C. 1681s-2 ( b ) ) Plaintiff incorporates by reference all preceding paragraphs as if fully stated herein.

Defendant GS Bank, as a furnisher of information to consumer reporting agencies, was notified by the CRAs of Plaintiffs dispute and was required by the FCRA to : Conduct a reasonable investigation regarding the disputed information, Review all relevant information provided by the CRAs, Report accurate and complete information to the CRAs or, if unable to verify, delete or modify the inaccurate information.

Defendant GS Bank failed to conduct a reasonable investigation, and failed to delete, modify, or correct the inaccurate information, thereby failing to meet its statutory duties under 1681s-2 ( b ).

As a direct and proximate result of Defendants failure, Plaintiff has suffered harm, including but not limited to : Damage to creditworthiness, Emotional distress, Lost financial opportunities. 
XXXX. Prayer for Relief WHEREFORE, XXXX XXXX XXXX XXXX respectfully requests that this Court enter judgment in his favor and grant the following relief : Actual damages for Defendants negligent violations of the FCRA under 15 U.S.C. 1681o ; Statutory and punitive damages for Defendants willful violations of the FCRA under 15 U.S.C. 1681n ; Attorneys fees, costs, and expenses pursuant to 15 U.S.C. 1681n, 1681o ; An injunction requiring Defendant to delete all inaccurate information from Plaintiffs credit report, cease reporting inaccurate information, and update all CRAs with corrected information ; and Such other and further relief as the Court deems just and proper.