Product: Money transfer, virtual currency, or money service

UNITED STATES XXXX XXXX XXXX XXXX OF FLORIDA PLAINTIFF, Plaintiff, v. 

CASH APP ( BLOCK, INC. ), Defendant. 

COMPLAINT FOR VIOLATIONS OF FEDERAL AND STATE CONSUMER PROTECTION LAWS Jury Trial Demanded INTRODUCTION 1. Plaintiff files this urgent complaint against Defendant Cash App ( Block , Inc. ) for multiple violations of federal and state consumer protection laws, including the Electronic Fund Transfer Act ( EFTA ), Regulation E, the Gramm-Leach-Bliley Act ( GLBA ), and other statutes. 


XXXX. Defendant 's inadequate safeguards, deceptive practices, and failure to provide appropriate dispute resolution have caused significant financial harm and distress to consumers, including the Plaintiff. 



JURISDICTION AND VENUE 3. This Court has jurisdiction pursuant to 28 U.S.C. 1331 because this action arises under federal law, including the EFTA, 15 U.S.C. 1693 et seq., and the GLBA, 15 U.S.C. 6801 et seq. 


4. Venue is proper under 28 U.S.C. 1391 because Defendant conducts business in this District, and the events or omissions giving rise to this action occurred within this District. PARTIES 5. Plaintiff is a consumer who re
lied on Defendants representations regarding the safety, security, and reliability of its platform for financial transactions.

6. Defendant, Cash App ( Block , Inc. ), is a financial services company headquartered at [ Defendant 's Address ], operating the Cash App platform, and conducting business nationwide, including within the State of Florida.

FACTUAL BACKGROUND 7. Plaintiff utilized Defendants platform for financial transactions based on assurances of safety and security.

8. Unauthorized transactions were detected on Plaintiff 's account. Despite promptly notifying Defendant and following dispute resolution procedures, Plaintiff received inadequate assistance. 


9. Defendant failed to investigate or reimburse the unauthorized transactions within the required timeframe, leaving Plaintiff financially vulnerable and distressed.

10. Defendants negligence, failure to safeguard accounts, and refusal to comply with federally mandated error resolution protocols have caused significant harm to Plaintiff.

CAUSES OF ACTION COUNT I Violation of the Electronic Fund Transfer Act ( EFTA ), 15 U.S.C. 1693 et seq. and Regulation E 11. Plaintiff incorporates all preceding paragraphs as if fully set forth herein. 


12. Defendant violated the EFTA and Regulation E by failing to investigate and resolve unauthorized transactions within the legally required timeframe.

13. Defendants non-compliance with error resolution obligations directly caused financial harm to Plaintiff.

COUNT II Violation of the Gramm-Leach-Bliley Act ( GLBA ), 15 U.S.C. 6801 et seq. 

14. Defendant failed to implement and maintain safeguards to protect consumers sensitive personal and financial information, as required by the GLBA Safeguards Rule.

15. This failure enabled unauthorized access to Plaintiffs account, leading to fraudulent activity and financial harm.

COUNT III Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ), 12 U.S.C. 5531 16. Defendant engaged in unfair and deceptive practices by : Misrepresenting the security of its platform. 

Failing to disclose limitations in its fraud prevention measures. 

Refusing to provide appropriate remedies for unauthorized transactions. 


17. These practices violate the Consumer Financial Protection Act ( CFPA ) and caused significant harm to Plaintiff.

COUNT IV Negligence 18. Defendant owed a duty of care to protect consumer accounts and financial information.

19. Defendant breached this duty by failing to : Prevent fraudulent activity on its platform.

Provide adequate customer service or remedial action.

20. Defendants negligence directly resulted in financial loss and emotional distress for Plaintiff.

PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests that this Court grant the following relief : 1. Compensatory damages in an amount to be determined at trial ; 2. Statutory damages under the EFTA, GLBA, and other applicable laws ; 3. Punitive damages for Defendants willful misconduct ; 4. Injunctive relief requiring Defendant to : Implement enhanced fraud detection and resolution procedures. 

Ensure compliance with all applicable federal laws.

5. Pre- and post-judgment interest ; 6. Attorneys fees and costs ; and 7. Any other relief the Court deems just and proper.

DEMAND FOR JURY TRIAL Plaintiff hereby demands a trial by jury on all issues so triable. 

DATED : XX/XX/year> Respectfully submitted,