Product: Credit reporting or other personal consumer reports

XXXX XXXX, XXXX, v. 

Experian Information Solutions , Inc. and XXXX XXXX XXXX XXXXXXXX Defendants. 

XXXX XXXX. XXXX AMENDED COMPLAINT FOR VIOLATIONS OF THE FAIR CREDIT REPORTING ACT ( FCRA ), PRIVACY RIGHTS, AND OTHER RELATED LAWS Plaintiff XXXX XXXX, residing at XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX, brings this action against Experian Information Solutions, Inc. ( Experian ) and XXXX XXXX XXXX XXXX XXXX  XXXX for violations of privacy rights, the Fair Credit Reporting Act ( FCRA ), and related consumer protection laws. Plaintiff alleges as follows : I. JURISDICTION AND VENUE This Court has jurisdiction under 28 U.S.C. 1331, as this case arises under the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq. 
Venue is proper under 28 U.S.C. 1391 because Defendants conduct substantial business in this district and the events giving rise to this Complaint occurred in this district. 
II. PARTIES Plaintiff : XXXX XXXX, an individual residing in XXXXXXXX XXXX. 
Defendant Experian Information Solutions , Inc. : A credit reporting agency headquartered at XXXX XXXX XXXX, XXXXXXXX XXXX XXXX XXXXXXXX. 
Defendant XXXX XXXX XXXX XXXXXXXX : A credit reporting agency headquartered at XXXX XXXX XXXXXXXX XXXX  XXXX, XXXXXXXX XXXX XXXX. 
III. FACTUAL ALLEGATIONS On or about XX/XX/year>, Plaintiff discovered that Defendants Experian and XXXX had unlawfully obtained and disseminated her private information without her knowledge or consent. 
Experian facilitated the unauthorized disclosure of Plaintiffs personal information, including her name, Social Security number, address, and other sensitive details, to XXXX XXXX and third-party creditors. 
Plaintiff had no prior business relationship or contractual agreement with XXXX, nor did she authorize XXXX to access or report her information. 
Defendants violated Plaintiffs privacy rights by obtaining and sharing her information for purposes of evaluating creditworthiness or extending credit, without Plaintiffs consent, in violation of the Fair Credit Reporting Act ( FCRA ). 
Despite Plaintiff disputing the accuracy and authorization of this information, Experian failed to conduct a reasonable investigation and continued reporting the disputed account ( XXXX XXXX XXXX ) as accurate. 
The ongoing reporting of this inaccurate and unauthorized information has caused Plaintiff to suffer : a. Reputational harm and loss of credit opportunities. 
b. Emotional distress and mental anguish. 
c. Increased risk of identity theft. 
IV. CLAIMS FOR RELIEF COUNT I : Violation of the Fair Credit Reporting Act ( FCRA ) Defendants violated 15 U.S.C. 1681b by obtaining and sharing Plaintiffs consumer report without a permissible purpose. 
Defendants violated 15 U.S.C. 1681s-2 ( b ) by failing to conduct a reasonable investigation into Plaintiffs disputes regarding inaccurate reporting. 
Defendants violated 15 U.S.C. 1681e ( b ) by failing to maintain reasonable procedures to ensure the accuracy of the information furnished. 
COUNT II : Invasion of Privacy Defendants unauthorized access, disclosure, and dissemination of Plaintiffs private information constitute an invasion of Plaintiffs privacy under California law. 
Plaintiff suffered emotional distress and reputational harm as a direct result of Defendants actions. 
COUNT III : Negligence Defendants negligently failed to protect Plaintiffs personal information from unauthorized access and misuse. 
This negligence caused Plaintiff to suffer damages, including emotional distress and an increased risk of identity theft. 
COUNT IV : Willful and Reckless Misconduct Defendants willfully and recklessly ignored Plaintiffs disputes and continued reporting inaccurate information, causing ongoing harm to Plaintiffs creditworthiness and privacy rights. 
V. DAMAGES As a direct result of Defendants unlawful actions, Plaintiff has suffered the following damages : Economic Damages : Loss of credit opportunities, reputational harm, and related expenses : {$750000.00}. 
Non-Economic Damages : Emotional distress and mental anguish : {>= $1,000,000}. 
Punitive Damages : To deter Defendants from engaging in similar misconduct in the future : {>= $1,000,000}. 
Statutory Damages : As provided under FCRA for willful violations : {$10000.00}. 
Attorneys Fees and Costs : Plaintiff seeks reimbursement for all reasonable legal fees and litigation costs incurred. 
VI. PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests that this Court : Award compensatory damages, including economic and non-economic damages, in the amount of {$1.00} XXXX. 
Award statutory damages under FCRA in the amount of {$10000.00}. 
Award punitive damages to deter Defendants reckless and willful misconduct in the amount of {>= $1,000,000}. 
Grant injunctive relief requiring Defendants to cease unauthorized reporting and implement procedures to ensure compliance with FCRA. 
Award Plaintiff reasonable attorneys fees and costs. 
Grant any further relief the Court deems just and proper. 
Dated : XX/XX/year> Respectfully Submitted, XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXXXXXX XXXXXXXX XXXX XXXX XXXXee attachments you been served Cease-and-Desist any reporting information until the judge make a ruling in this matter