Product: Credit reporting, credit repair services, or other personal consumer reports

UNITED STATES DISTRICT COURT for the XXXX XXXX XXXX Georgia XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, GA XXXX ______________________ XXXX XXXX XXXX Plaintiffs -vs Complaint for Violation of Fair Credit Reporting Act 1681 ( e ) ( g ) ( q ) ( r ) Experian Information Solutions , Inc Defendants ______________________________ Complaint forViolation of Fair Credit Reporting Act 1681 et, set I. INTRODUCTION 1.Plaintiff ( XXXX XXXX XXXX XXXX the ( Plaintiffs ) XXXX protected member filed complaint on behalf of themselves and all others similarly situated, ( XXXX protected member '' ) had been subjected to or been the subject of unfair and deceptive business practices ; failure to conduct a reasonable investigation reinvestigation within 30 days limit imposed a duty 1681 ( i ) b ( c ) ( 1 ) ( B ) ( e ) ( g ) ( q ) ( r ) in continuance in violation of 1681b-s ( 2 ) ( a ) ( b ) ( 8 ).

2.Plaintiff XXXX protected member protected by ( U.S. Government ) under The Attorney General is authorized to file a federal lawsuit against any person ( s ) or entry who engaged in a pattern or practice of violating this law ( 50 U.S.C. 4041 ( a ) ( 2 ) .Attorney General may file a suit where the facts at hand raise an issue of monetary damages on behalf of individual service members4041 ( b ) ( 2 ) ; has the authority to seek civil penalties ; equitable relief, declaratory and injunctive relief. 

3.Plaintiff asserted his constitutional rights ; when Defendants failure conduct a reinvestigation imposed duty 1681 ( i ) ( e ) ( b ) but rather forwarding to ( CRA ) Credit Reporting Agency Experian Information Solutions ( EIS ) took adverse action against ( " the XXXX protected member '' ) based on his protectecd characteristics or permanent impairments. 

4. The Defendants made unauthorized disclosure of ( the XXXX protected members ) under false pretenses violated 1681q 1681r.

knowingly and willfully obtains the consumers ( XXXX protected members ) ( PII ) from Experian affiliates ; a third party consumer reporting agency under false pretenses or unauthorized disclosure of ( the XXXX protected member ) violated 1681q 1681r. 

Preliminary Statement 5.Plaintiff filed this action for damages brought by an individual consumer against the Defendant for violations of the Fair Credit Reporting Act ( FCRA ) 15 U.S.C. 1681, et seq., as amended. 
6.Plaintiff brought this diversity libel action against Defendants ; that made patently false statements with the actual knowledge of its errors ; defame and libel ( XXXX protected member ). 

Parties 7. Plaintiff is an adult individual who resides in State of Georgia.

8. Defendant ( s ) is a business entity and consumer reporting agency that regularly conducts business in the State of California and Sate of Georgia.

Jurisdiction and Venue 9. Jurisdiction of this Court arises under 15 U.S.C. 1681p ; 15 U.S.C. 1681q 1681r and 28 U.S.C. 1331.

10. Venue lies properly in this district pursuant to 28 U.S.C. 1391 ( b ).

Factual Allegations 11. The Defendant has been reporting derogatory and inaccurate statements and false or misleading information relating to Plaintiff and Plaintiffs credit history to third parties ( inaccurate information ) from at least XX/XX/2021 through present. The inaccurate information includes a public record of identifying personal ; confidential; sensitive and classified information. 
12. The Defendants inaccurate information negatively reflects upon the Plaintiff, ( the Class Member ) ; Plaintiffs credit repayment history ; Plaintiffs financial responsibility as a debtor and Plaintiffs creditworthiness. Defendants inaccurate information is consists of a public record that does not belong to the Plaintiff, and that actually belong to at least one other consumer. Due to Defendants faulty procedures, Defendant mixed the credit file of Plaintiff and that of at least another consumer with respect to the inaccurate information and other personal identifying information.

13. The Defendant has been reporting the inaccurate information through the issuance of false and inaccurate credit information and consumer credit reports that it has disseminated to various persons and credit grantors, both known and unknown. Defendant has repeatedly published and disseminated consumer reports to such third parties from at least XX/XX/2021 through the present 14. Plaintiffs credit report and file has been obtained from Defendant and has been reviewed by prospective and existing credit grantors and extenders of credit, and the inaccurate information has been a substantial factor in precluding Plaintiff from receiving different credit offers and opportunities, known and unknown. Plaintiffs credit reports have been obtained from Defendant by such third parties from at least XX/XX/2021 through the present. 
15. As a result of Defendants conduct, Plaintiff has suffered actual damages in the form of credit denial or loss of credit opportunity, credit defamation and emotional distress, including anxiety, frustration, embarrassment; and humiliation from loss of security clearance.

16. At all times pertinent hereto, Defendant was acting by and through its agents, servants and/or employees who were acting within the course and scope of their agency or employment, and under the direct supervision and control of the Defendant herein.

17. At all times pertinent hereto, the conduct of the Defendant, as well as that of its agents, servants and/or employees, was intentional, willful, reckless, and in grossly negligent disregard for federal law and the rights of the Plaintiff herein.

Count One- Violations of the FCRA 18.Plaintiff incorporates the foregoing paragraphs as though the same were set forth at length herein.

19. At all times pertinent hereto, Defendant was a person and consumer reporting agency as those terms are defined by 15 U.S.C. 1681a ( b ) and ( f ) 20. At all times pertinent hereto, the Plaintiff was a consumer as that term is defined by 15 U.S.C. 1681a ( c ).

21. At all times pertinent hereto, the above-mentioned credit reports were consumer reports as that term is defined by 15 U.S.C. 1681a ( d ) ; 1681n and 15 U.S.C. 1681o ; 22.Pursuant to 15 U.S.C. 1681n and 15 U.S.C. 1681o, Plaintiff ( the XXXX XXXX ) victim of identiy theft; resulted from ( the defendants ) violate 1681q 1681r.

Prohibition on Sale or Transfer of Debt caused by Identity Theft ( 1 ) No person shall sell ; transfer or place for collections ; a debt having been flagged as ( fraudulent account ) under 1681c ( 1 ) ( 2 ) ( 5 ) ( 6 ) as result of identity theft. [ Experian Data Breach Class Action Lawsuit is XXXXXXXX XXXX XXXX. v. Experian XXXX XXXX, Case No. XXXX. ]