Product: Vehicle loan or lease

UNITED STATES XXXX XXXX XXXX XXXX XXXX CALIFORNIA XXXX XXXX, Plaintiff, v. 
Toyota Motor Credit Corporation, Defendant. 
XXXX XXXX. : XXXX AMENDED COMPLAINT FOR VIOLATIONS OF THE FAIR CREDIT REPORTING ACT ( FCRA ), TRUTH IN LENDING ACT ( TILA ), FRAUD, AND OTHER RELATED CONSUMER PROTECTION STATUTES Plaintiff XXXX XXXX, residing at XXXX XXXX XXXX, XXXX XXXX XXXX XXXX, CA XXXX XXXX files this Amended Complaint against Toyota Motor Credit Corporation XXXX Defendant ) and alleges as follows : I. JURISDICTION AND VENUE This action is brought under the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681, Truth in Lending Act ( TILA ), 15 U.S.C. 1601, Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692, and other relevant consumer protection laws.

This Court has jurisdiction pursuant to 28 U.S.C. 1331 as this case involves federal questions under the FCRA, TILA, and FDCPA. 
Venue is proper in this judicial district because Defendant conducts substantial business in this district, and the actions giving rise to this complaint occurred here. 

II. PARTIES Plaintiff : XXXX XXXX, an individual and resident of XXXX, California. 
Defendant : Toyota Motor Credit Corporation, headquartered at XXXX XXXX XXXX XXXX XXXX, TX XXXX, regularly engages in consumer vehicle financing. 

XXXX. FACTUAL BACKGROUND On or about XX/XX/year>, Plaintiff entered into a vehicle financing agreement with Defendant for the purchase of a vehicle. 
The first vehicle provided under the agreement was defective and posed safety risks, including a gas leak, necessitating a replacement vehicle. 
Defendant replaced the vehicle but inflated the financing amount and included unauthorized add-ons, such as : a. [ List Add-Ons, e.g., XXXX insurance, service contract ]. 
b. [ Additional fees or items ]. 
Defendant failed to disclose critical terms, including finance charges, the Annual Percentage Rate ( APR ), and the security interest in the vehicle, in violation of TILA.

Defendant inaccurately reported Plaintiffs account as delinquent ( 90-119 days late ) to credit bureaus, despite Plaintiff making timely payments. 
Plaintiff repeatedly disputed the inaccuracies with Defendant and credit reporting agencies, providing evidence of timely payments, yet Defendant failed to correct the errors.

Defendants actions have caused Plaintiff significant financial harm, emotional distress, and reputational damage.

IV. CLAIMS FOR RELIEF Count I : Violation of the Fair Credit Reporting Act ( FCRA ) Defendant, as a furnisher of credit information, violated 15 U.S.C. 1681s-2 ( b ) by failing to conduct a reasonable investigation into Plaintiffs disputes regarding inaccurate reporting. 
Defendants failure to investigate and correct false information caused Plaintiff harm, including credit denials, financial losses, and emotional distress. 
Count II : Violation of the Truth in Lending Act ( TILA ) Defendant violated TILA by failing to provide clear and accurate disclosures of finance charges, APR, and security interests in the vehicle.

Plaintiff was misled into entering a financing agreement with hidden costs and unauthorized charges.

Count III : Fraud Defendant knowingly misrepresented and concealed material terms of the financing agreement, including inflated pricing and unauthorized add-ons.

Plaintiff reasonably relied on Defendants representations, resulting in financial harm and credit damage.

Count IV : Violation of the Fair Debt Collection Practices Act ( FDCPA ) Defendant engaged in deceptive practices in the collection of alleged debts by inaccurately reporting Plaintiffs account as delinquent. 
Defendants actions violated 15 U.S.C. 1692, causing financial and emotional harm.

V. PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests that this Court enter judgment against Defendant and grant the following relief : Compensatory Damages : Economic damages : {$15000.00}. 
Non-economic damages : {$25000.00}. 
Statutory Damages : As provided under FCRA, TILA, and FDCPA : {$10000.00}. 
Punitive Damages : To deter Defendants malicious and fraudulent conduct : {$50000.00}. 
Injunctive Relief : Order Defendant to correct inaccurate credit reporting and cease violations of consumer protection laws. 
Attorneys Fees and Costs : Reimbursement for all reasonable fees and litigation costs incurred. 
Any other relief the Court deems just and proper. 

Dated XX/XX/year> Respectfully submitted, XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXXXXXX, CA XXXX