Product: Credit reporting or other personal consumer reports

UNITED STATES DISTRICT COURT FOR THE [ District ] XXXX XXXX, Plaintiff, v. 
JPMCB CARD ( CHASE ), Defendant. 
COMPLAINT PARTIES AND JURISDICTION Plaintiff : XXXX XXXX, residing at XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX, FL XXXX ; Date of Birth : XXXX. 
Defendant : JPMCB Card ( Chase ), a banking and credit services company headquartered in XXXX XXXX, NY, engaging in consumer credit reporting and debt collection activities across the United States.

Jurisdiction : This Court has jurisdiction under 28 U.S.C. 1331, as this case arises under federal statutes : the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692c ( c ), and the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681.

FACTUAL BACKGROUND Cease Communication Request : On [ Date of Written Notification ], Plaintiff sent a written request to Chase, directing the Defendant to cease all communication regarding a disputed debt under the authority of 15 U.S.C. 1692c ( c ).

Continued Communication : Despite the clear written cease-communication request, Chase continued to attempt debt collection by contacting Plaintiff, violating FDCPA provisions under 15 U.S.C. 1692c ( c ).

Inaccurate Credit Reporting : JPMCB inaccurately reported Plaintiffs account status to credit bureaus, including [ XXXX, XXXX, XXXX ], by misrepresenting late payments and indicating an erroneous charge-off status. Despite Plaintiff disputing these inaccuracies with Chase and the credit bureaus, the errors remained uncorrected, resulting in negative marks on Plaintiffs credit. 
CLAIM I : VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1692c ( c ) Elements Satisfied : Debt Collection Activity : Defendant, acting as a debt collector in this case, engaged in efforts to collect an alleged consumer debt from Plaintiff.

Cease-Communication Request : Plaintiff provided a valid, written cease-communication notice to Defendant, as per 15 U.S.C. 1692c ( c ).

Prohibited Communication : Defendant contacted Plaintiff after receiving the cease-communication request without meeting any permissible exceptions under the FDCPA.

Damages : Plaintiff suffered actual damages, including emotional distress and frustration, as a result of the unlawful communications. Plaintiff seeks statutory damages under 15 U.S.C. 1692k, as well as actual damages and reasonable attorneys fees.

CLAIM II : VIOLATION OF THE FAIR CREDIT REPORTING ACT, 15 U.S.C. 1681e ( b ) AND 1681s-2 ( b ) Elements Satisfied : Inaccurate Reporting : Defendant inaccurately reported negative information on Plaintiffs credit report, including false late payment entries and an improper charge-off designation.

Failure to Investigate and Correct : Despite Plaintiffs disputes sent to both Defendant and the credit reporting agencies, Defendant did not conduct a reasonable investigation or correct the inaccuracies, violating 15 U.S.C. 1681s-2 ( b ).

Damages : Defendants actions caused Plaintiff financial and emotional harm, resulting in a lower credit score and potential credit denials. Plaintiff seeks statutory damages, actual damages, punitive damages, and reasonable attorneys fees and costs.

RELIEF REQUESTED WHEREFORE, Plaintiff requests that this Court enter judgment in favor of Plaintiff and against Defendant as follows : a. Statutory damages under 15 U.S.C. 1692k ( a ) ( 2 ) ( A ) for FDCPA violations.

b. Actual damages for Plaintiffs emotional distress and financial harm.

c. Punitive damages under the FCRA for willful non-compliance. 
d. Reasonable attorneys fees and costs incurred in bringing this action. 
e. Any additional relief the Court deems just and proper.