Product: Credit reporting or other personal consumer reports

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF INTRODUCTION This is an action for damages and injunctive relief brought by the Plaintiff, XXXX XXXX XXXX XXXX, against the Defendants, Wilshire Commercial Capital, and major consumer reporting agencies, namely XXXX, XXXX, and XXXX, for violations of the Fair Credit Reporting Act ( FCRA ) 15 U.S.C. 1681 et seq., arising from the inaccurate reporting of Plaintiff 's credit information and failure to comply with federal requirements regarding accurate consumer reporting. 
PARTIES Plaintiff : XXXX XXXX XXXX XXXX is a natural person residing at XXXX XXXX XXXX XXXX Apt XXXX, XXXX, TX XXXX. His date of birth is XX/XX/XXXX, and he is a " consumer '' as defined by 15 U.S.C. 1681a ( c ).

Defendant Wilshire Commercial Capital is a financial institution offering lending and capital services to consumers and businesses. Wilshire Commercial Capital is subject to the requirements set forth in the FCRA as a " furnisher '' of information to consumer reporting agencies. 
Defendants XXXX, XXXX, and XXXX are consumer reporting agencies as defined by 15 U.S.C. 1681a ( f ), regularly engaged in the business of assembling and evaluating consumer credit information.

JURISDICTION AND VENUE T

his Court has jurisdiction over this matter pursuant to 15 U.S.C. 1681p and 28 U.S.C. 1331, as the matter involves federal questions regarding the Fair Credit Reporting Act.

Venue is proper in this District under 28 U.S.C. 1391 ( b ) because a substantial part of the events giving rise to the claims occurred in this District, and the Plaintiff resides in this District. 
FACTUAL ALLEGATIONS On or about XX/XX/XXXX, Plaintiff obtained a consumer credit report from XXXX, XXXX, and XXXX, which included inaccurate information furnished by Wilshire Commercial Capital.

The inaccurate information related to Plaintiffs account with Wilshire Commercial Capital, specifically : Inaccurate Payment History : The consumer report reflects a payment history that inaccurately suggests delinquency beginning in XX/XX/XXXX, which does not accurately document Plaintiffs payment behavior on this account. 
Incorrect Reporting of Last Payment : The consumer report fails to accurately reflect the last payment made by Plaintiff on XX/XX/XXXX. 
Date of First Delinquency : The report inaccurately lists the date of first delinquency, creating a misleading representation of the accounts status and suggesting a charge-off that is unsupported by the actual payment records. 
Plaintiff disputed the inaccurate information directly with Defendants XXXX, XXXX, and XXXX, as well as Wilshire Commercial Capital, but Defendants failed to perform a rea

sonable investigation and continued to report the false information. LEGAL CLAIMS COUNT I : VIOLATION OF THE FAIR CREDIT REPORTING ACT ( 15 U.S.C. 1681 et seq. ) Plaintiff repeats and realleges the allegations set forth in Paragraphs XXXX through XXXX as though fully set forth herein. 
Defendants Wilshire Commercial Capital, XXXX, XXXX, and XXXX willfully and/or negligently failed to comply with the requirements of the FCRA, including but not limited to the duty to provide accurate and complete information under 15 U.S.C. 1681s-2 ( a ) ( 1 ). 
Wilshire Commercial Capital violated the FCRA by : Failing to accurately report the payment history, including the dates of first delinquency and last payment. 
Furnishing information to consumer reporting agencies that it knew or should have known was inaccurate. 
XXXX, XXXX, and XXXX violated the FCRA by : Failing to conduct a reasonable investigation into Plaintiffs disputes concerning the accuracy of information. 
Continuing to report inaccurate information despite receiving notice of its inaccuracy from Plaintiff.

As a direct and proximate result of Defendants violations, Plaintiff has suffered damages, including harm to his creditworthiness, emotional distress, and inconvenience, in an a
mount to be determined at trial.

COUNT II : VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT ( 15 U.S.C. 1692c ) Plaintiff repeats and realleges the allegations set forth in Paragraphs XXXX  through XXXX as though fully set forth herein. 
Wilshire Commercial Capital, acting as a furnisher of information to consumer reporting agencies, engaged in practices that misled and harmed the Plaintiff by inaccurately reporting payment history.

Plaintiff notified Wilshire Commercial Capital and the consumer reporting agencies of the dispute and inaccuracies ; however, Defendants failed to rectify the inaccuracies or verify the accuracy of the data as required under federal law.


PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in his favor and against Defendants as follows : A. Award actual, statutory, and punitive damages under 15 U.S.C. 1681n and 1681o ; B. Grant injunctive relief ordering the Defendants to correct all inaccuracies in Plaintiffs credit reports ; C. Award reasonable attorneys fees and costs pursuant to 15 U.S.C. 1681n ( a ) ( 3 ) ; D. Any other relief that the Court deems just and proper.

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