Product: Credit reporting or other personal consumer reports

COMPLAINT FOR VIOLATION OF THE FAIR CREDIT REPORTING ACT INTRODUCTION This is an action for damages brought by Plaintiff XXXX XXXX, an individual, against Defendant Toyota Motor Credit Corporation ( Toyota ), for violations of the Fair Credit Reporting Act, 15 U.S.C. 1681 et seq. ( " FCRA '' ). 
Defendant Toyota failed to conduct a reasonable investigation into Plaintiffs dispute regarding its erroneous reporting of her account status, in violation of 15 U.S.C. 1681s-2 ( b ). 
JURISDICTION AND VENUE This Court has jurisdiction under 15 U.S.C. 1681p and 28 U.S.C. 1331, as this action arises under federal law. 
Venue is proper in this District under 28 U.S.C. 1391 ( b ) because Toyota Motor Credit Corporation is subject to personal jurisdiction in this District and a substantial part of the events giving rise to the claim occurred here. 
PARTIES Plaintiff XXXX XXXX is a consumer as defined by the FCRA, 15 U.S.C. 1681a ( c ), residing at XXXX XXXX XXXX XXXX XXXX XXXX, XXXX, NY XXXX. 
Defendant Toyota Motor Credit Corporation is a furnisher of credit information, with its principal address at : Toyota Motor Credit Corporation XXXX XXXX XXXX XXXX, GA XXXXToyota regularly furnishes credit information to consumer reporting agencies such as XXXX, XXXX, and XXXX . 
FACTUAL ALLEGATIONS Plaintiff obtained her credit report from the three major consumer reporting agencies ( XXXX, XXXX, and XXXX ) and discovered inaccuracies related to her Toyota Motor Credit Corporation account ( Account Number : XXXX ). 
Specifically, Defendant Toyota inaccurately reported the date of last payment on Plaintiffs account inconsistently, with XXXX and XXXX reporting XX/XX/year>, while XXXX reported XX/XX/year>. 
Toyota also inaccurately reported the payment history, indicating a 60-day late status on all three credit reports as of XX/XX/year>, without sufficient investigation into the accuracy of such information. 
Plaintiff disputed the inaccurate information with the consumer reporting agencies and requested that Toyota conduct a reasonable investigation into her claim. 
Upon information and belief, Toyota failed to conduct a reasonable investigation, instead relying solely on its internal records without evaluating Plaintiffs account history or verifying the accuracy of the reported information. 
Defendants actions caused Plaintiffs credit score to decline, affecting her creditworthiness and resulting in economic and reputational harm. 
COUNT I VIOLATION OF THE FAIR CREDIT REPORTING ACT ( 15 U.S.C. 1681s-2 ( b ) ) Plaintiff re-alleges and incorporates by reference each of the above paragraphs as though fully set forth herein. 
Under 15 U.S.C. 1681s-2 ( b ), after receiving notice of a dispute from a consumer reporting agency, a furnisher is required to conduct a reasonable investigation to verify the accuracy of the disputed information. 
Toyota Motor Credit Corporation received notice of Plaintiffs dispute from the consumer reporting agencies regarding the inconsistencies in payment history and last payment date. 
Toyota willfully and/or negligently failed to conduct a reasonable investigation of the disputed information and instead verified inaccurate information to consumer reporting agencies without taking any corrective action. 
Defendant 's inadequate investigation has caused Plaintiff to suffer harm, including but not limited to, lowered credit scores, denials of credit, and other damages. 
PRAYER FOR RELIEF WHEREFORE, Plaintiff XXXX XXXX requests that judgment be entered in her favor and against Defendant Toyota Motor Credit Corporation for the following relief : a. Actual damages in an amount to be determined at trial ; b. Statutory damages for each violation of the FCRA ; c. Punitive damages as allowed under the FCRA ; d. Attorneys fees and costs as provided by 15 U.S.C. 1681n and 15 U.S.C. 1681o ; e. Such other relief as this Court deems just and proper.