Product: Credit reporting, credit repair services, or other personal consumer reports

At all times pertinent hereto, consumer is /was a consumer as that term is defined by 15 U.S.C. 1681a ( c ). 

At all times pertinent hereto, the above-mentioned credit reports were consumer reports as that term deemed by 15 U.S.C. 1681a ( d ). 

Experian sold Plaintiffs ' and Class Members ' highly sensitive, confidential ( i ) actual identity theft and identity fraud ( ii ) invasion of privacy ( iii ) failure and refusal to safeguard and protect consumer. 

Experian failure to safeguard and protect privacy of the ; consumer credit information including encryption ; electronic and procedural safeguards to protect Plaintiffs personal information to date. 

Consumer invoking said action for actual damages ; statutory damages and punitive damages brought by consumer, against Experian Information Solutions , Inc., Experian Holdings, Experian Financial Services ; Experian Background. 

Experian has been reporting derogatory and inaccurate statements and information relating to Plaintiffs credit history to third parties ( hereafter the inaccurate information ). 

Experian access, sold ; aggregate consumer protected members highly sensitive and confidential information and regulated consumer, financial, and personal records including consumer credit information ; social security numbers ( collectively, PII ) were sold PII to other identity theft. 

Experian accountable for his/her conduct for failure to ensure Experian never engages in this egregious conduct again. ( CRA ) shall redress defendants faulty process, mixing the credit of consumer files and credit information with other consuming identifying information causing Security Lapse. 


Experian admonition Security Lapse incurred when permitted a known convicted identity thief or black market PII trafficker, and computer hacker to access, sold ; aggregate consumer protected members highly sensitive and confidential information and regulated consumer, financial, and personal records including consumer credit information ; social security numbers ( collectively, PII ) and sold. The data security lapses willfully and wrongfully disclosed highly sensitive and confidential information of consumer compromised rights of privacy. 

Experian accurate reporting of information negatively reflected upon consumer credit repayment history ; financial responsibility as a debtor adversely impacted his credit worthiness. The inaccurate information consists of accounts and/or tradelines that do not belong to the consumer to date Experian and Experian Holdings, Experian Financial Services ; Experian Information Solutions ; Experians ( hereafter Experian ) a person and a consumer reporting agency deemed by 15 U.S.C. 1681a ( b ) and ( f ) engaged in pattern or practice of Mixing Consumers Credit Report and Reporting False Accounts violated or in violation of the Fair Credit Reporting Act ( hereinafter the FCRA ), 15 U.S.C. 1681, et seq for {$15000.00}. Agency repeatedly and persistently data-file sharing or reciprocity agreement between XXXX  and XXXX. 

CRA failure to follow reasonable procedures which assure that the previous and current consumer reports disclose to date met the standard of maximum possible accuracy. 15 U.S.C. 1681e ( b ) in violation of Fourth Amendment [ Boyd vs United States ]. 

CRA failure to safeguard and protect consumer credit information or report accuracy of information timely ; 15 U.S.C. 1681e ( b ) undermine the public trust or confidence entrusted upon said agency .Experian and Experian Holdings , Experian Financial Services ; Experian Information Solutions having stewardship of Plaintiffs personal information having partnership with known convicted identity thief or black market trafficking of protected service member ( PII ) when computer hacker access ; aggregate ; repacked and sold ( protected member ) highly sensitive information to be collected through underground websites or web scraping violated or in violation of consumer rights of privacy to date. 


Experian admonition having actual or advance knowledge that merger of ( XXXX ; XXXX ) compromised consumer personal information when entered willfully into reciprocity agreement that granted or facilitated black marketer in willfully and wrongfully obtain and access my ( PII ) ; collected through underground websites or web scraping that violated my rights of privacy. Experian actions or inactions when failure to notify consumer of Security Lapse ; a breach of data that made known or publication of inaccurate or false information ; malign the consumer information to date. 

Experian is liable to consumer for willfully and negligently failing to comply with the requirements imposed on a consumer reporting agency of information pursuant to 15 U.S.C. 1681e and 1681i and 15 U.S.C. 1681n and 15 U.S.C. 1681o. 

Experian failure to employ adequate customer data security measures recover FCRA statutory and punitive damages ; pursuant to 15 U.S.C 1681 n ( a ) [ a ] ny person who willfully fails to comply with any requirement imposed under this subchapter with respect to any consumer is liable to that consumer for actual, statutory, or punitive damages. See Harris v. Mexican Specialty Foods , Inc., 564 F.3d 1301, 1306 ( XXXX Cir.XX/XX/XXXX ). 

The Supreme Court has held that any reckless disregard of any consumer/subscriber protected rights under FCRA does qualify as willful violation of 1681n ( a ). XXXX, 551 U.S. at 71, 127 S. Ct. at 2216 ; See also XXXX , 564 F.3d at 1310 ( A violation is willful for the purposes of the FCRA ; whe Experian knowingly and willfully violated the terms of the Act with actual or personal knowledge is reckless disregard for the law. 

The above describe parties made an admonition its agents ; Experian and Experian Holdings, Experian Financial Services ; Experian Information Solutions ; Experians agents, subsidiaries, successors, predecessors ; subsidiaries and its parents having controlling interests or ownership ; current and former employees, officers, directors having enjoyed the benefits ; services ; privileges of using consumer ( PII ) through Experian reciprocity agreement shared between XXXX and XXXX. 

Experian deficient policies was the moving force behind the constitutional violations to date. 

Experian admitting having unlawfully obtain consumers ( PII ) were mixed during Security Lapse. Security Lapse arose during Experian data-file sharing or reciprocity agreement between XXXX  and XXXX  admitted before courts consumer was the victim of criminal impersonation. ( Johnson v. County of Dakota, 510 N.W.2d 237, 240 ( Minn. Ct. App. XX/XX/XXXX). [ XXXX  and XXXX  ]. 

CRA and its agents, subsidiaries, successors, predecessors ; subsidiaries of Experian or its parents having controlling interests or ownership ; current and former employees ; officers ; directors and other ( third party/parties ) facilitated cybercriminal acquisition. The cybercriminal acquisition aggregated, repackaged, resell and distributed my ( PII ) through data base-file sharing or reciprocity agreement between failure to protect and safeguard consumer ( PII ). 

COUNT I I EXPERIAN VIOLATIONS OF FCRA CALIFORNIA UNFAIR LAW CAL. BUS. & PROF. CODE 17200, 17300 et seq. ) 46. California Unfair Competition Law, CAL. BUS. & PROF. CODE 17200,17300 et seq ; ( UCL ), prohibits any false or misleading advertisement, unlawful, unfair or fraudulent business ; acts or practices ; known to be unfair, deceptive or untrue prohibited by Chapter 1 Section 17200 defined by UCL. 

Consumer invoking Ga. Code Ann . 10-1-910 to -912 as result of CRA above-described wrongful actions, inaction, omissions, want of ordinary care. 

Pursuant to 1681i ( a ) consumer reporting agency ( Experian ) failure to conduct an unbiased reasonable reinvestigation of Petitioners written complaints ( s ) during XXXX XXXX through XX/XX/XXXX ; failure to remove false reporting about the consumers credit reports or consumer reports resulted in derogatory account ( s ) on his credit report to public shall be culpable for a consumer to recover actual damages. 

Experian knew or reasonably known the account was fraudulent date of reported but kept reporting as accurate ; such false reporting violated Section 13 ( b ) of ( FTC Act ) ; 15 U.S.C. 53 ( b ), Standards for Safeguarding Customer Information ( Safeguards Rule ) ; 16 C.F.R. Part 314 ; Sections 501-504 of the Gramm-Leach-Bliley Act ( GLB Act ) ; 15 U.S.C. 6801- 6804 ; 15 U.S.C. 45 ( a ). 

Experian and Experian Holdings, Experian Financial Services ; Experian Information Solutions ; Experians agents, subsidiaries, successors, predecessors ; subsidiaries XXXX XXXX XXXX herein ( XXXX XXXX XXXX or XXXX ) which Experian or its parents having controlling interests or ownership ; current and former employees, officers, directors and registered agent XXXX XXXX on formal notice my previous FTC complaint ; mixing of files and data information file sharing agreement to date, went unresponsive. 

Complaint Against Experian for Mixing Credit Files and Information, False Credit Reporting COUNT III Experian Violated Section 1681g Deficient Disclosures and Fraudulent Concealment Experian actors ; failed to disclose known breach of data timely or concealment of Security Lapse violated or in violation of Plaintiffs trust, violated Section 1681g ( a ) ( l ). 

Experian had advance knowledge of concealment of agency above-describe violation of the Plaintiffs trust or disclosures that shown an inaccurate account of the consumer credit worthiness ; when known in fact consumer credit worthiness ; was gross fabrication about the consumer to date. 

Experian ; Experian Senior General Counsel ; Experian 's agents and directors ; entrusted with the stewardship over my ( PII ) violated that chain of trust, when failed to disclose such breach of data timely ; violated Section 1681g ( a ) ( l ) .The deficient disclosures shown an inaccurate account of consumer credit worthiness, specifically misled banks and lenders into believing that the information disclose by Experian was accurate when in fact was gross fabrication about the consumer to date. 

Experian took active steps to conceal its above-described wrongful actions, inaction, omissions, want of ordinary care, nondisclosures of the Security Lapse. Experian went so far to exclude consumer from discovery of the data-file sharing agreement and concealment of its above-described unlawful conduct to date from consumer would have shown Experian failure to exercised due diligence by not vetting XXXX during merger. 

IV. Harm Suffered by Consumer Experians arbitrary decision to remain silent of the breach of data ; prohibited consumer from discovery of these failures and afforded the opportunity to independently investigate the negative information in his file for completeness, accuracy and potential fraud. 

Experian 's failures subjected consumer to injury and the deprivation of his right to privacy and accuracy or afforded the opportunity to exercise his right to object under FCRA Section 1681 b ( e ) or the sharing of his data between ( XXXX  ) and ( XXXX  ) under Section l68la ( d ) ( 2 ) ( A ) ( iii ). 

Experian deficient procedures and practices arose during merger of ( XXXX cause the mismatching of consumer credit information and files belonging to another subscriber or consumer ; resulted in identity theft/fraud pursuant to 1681 ( a ) ( d ). 

Experian intentionally concealed its above-described wrongful conduct ; proven their motives were pretext for non-disclosure of material information that would reveal to consumer and the public ; failure to exercised due diligence or care by not vetting XXXX during the merger met all applicable statutes under the fraudulent concealment doctrine. 

Experian took active steps to conceal its above-described wrongful actions, inaction, omissions, want of ordinary care, nondisclosures, and the resulting Security Lapse. Such concealment of Experian above-described unlawful conduct in its possession, custody and control excluded consumer in discovery of data-file sharing agreement revealed timely to consumer ; supports and substantiates Experian failure to exercised due diligence resulting in Security Lapse. Experian conceal its above-described unlawful conduct are in its possession, custody, and control, to the exclusion of consumer and further discovery. 

Experian repeatedly and persistently violated Section 1681g Disclosures and Section 168la ( d ) ( 2 ) ( A ) ( i ) and ( ii ) disclosing information collected from XXXX XXXX and verify the accuracy of furnisher information despite knowingly the consumer was the subject of mixing of files and information. 

Experian violated Section 1681g Disclosures ( 1 ) failure to notify consumer that XXXX aggregated, repackage and distributed erroneous information about him from Consumer View database ; XXXX XXXX and other databases Experian owns, controls and/or maintains. CRA made it functionally impossible for consumer to discover or take advantage of the self-policing remedies provided to him under the FCRA, therefore violated consumer 's statutory and constitutional right to privacy under Section 1681g. 

V. Experian Cause Fraud by using Consumer PII Without Authorization Experian admitted intended to use and did used consumer PII to obtain good and services in consumer name through websites supports and substantiates criminal fraud. 

Ga. Code Ann . 10-1-910 to -912 defines any unauthorized acquisition that compromises the security, confidentiality or integrity of the covered info by transmitting or otherwise communicating information concerning individuals for the primary purpose of furnishing personal information to nonaffiliated third parties for purpose not permissible. 

Experian willfully and recklessly violated 15 U.S.C. 1681 ( b ), 15 U.S.C. 1681a ( d ) ( 3 ), 15 U.S.C. 1681b ( a ) ; ( g ) and 15 U.S.C. 1681c ( a ) ( 6 ) failing to identify ; implement ; maintain and monitor proper data security measures, policies, procedures ; software and hardware systems to safeguard and protect consumer PII. 

Experian above-described wrongful actions, inaction and omissions whether directly and proximately caused Security Lapse resulted in the willful and wrongful dissemination of consumer PII into the public domain for no permissible purpose under FCRA. 

Experian above-described actions violated ( 15 U.S.C. 1681 ( a ) ( 3 ) ) ( a ) ( 4 ) failure to ensure accountability and transparency in protection of consumer 's right to privacy. The failure to safeguard and protect consumer PII ; ( ii ) properly conduct its due diligence prior to acquiring XXXX and XXXX ; ( iii ) properly investigate the hacker or black marketer XXXX and his fraudulent operations after learning about him ; ( iv ) not promptly notify consumer PII was wrongly accessed and/or obtained without authorization cause Security Lapse. Such willful conduct and reckless behavior prevented consumer timely notification about the Security Lapse which, in turn, inflicted additional economic damages and other actual injury and harm on consumer. 

Experian willful and wanton negligence violated or in violation of Section 1681 ( e ) ; Section1681 ( i ) ; Section1681 ( g ) and Section1681 ( o ).