Product: Credit reporting or other personal consumer reports

COMPLAINT Plaintiff, XXXX XXXX XXXX, by and through the undersigned attorney, hereby files this Complaint against Defendant LVNV Funding LLC, and alleges as follows : JURISDICTION AND VENUE This action arises under the Truth in Lending Act ( TILA ), 15 U.S.C. 1601 et seq., and the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq..

This Court has jurisdiction pursuant to 28 U.S.C. 1331.

Venue is proper in this judicial district pursuant to 28 U.S.C. 1391 ( b ), as the Defendant conducts business in this district and a substantial part of the events giving rise to the claims occurred within this district. 
PARTIES Plaintiff : XXXX XXXX XXXX, a consumer residing at XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX, NM XXXX, born XX/XX/XXXX. 
Defendant : LVNV Funding LLC is a financial entity that purchases debt and reports consumer debt to credit reporting agencies, located at C/O Resurgent Capital Services , XXXX XXXX XXXX, XXXX, SC XXXX. 
FACTUAL BACKGROUND On or about XX/XX/XXXX, Plaintiff became subject to a debt allegedly owned and serviced by Defendant, LVNV Funding LLC. 
Defendant failed to provide Plaintiff with accurate and clear disclosures about her debt and violated Plaintiffs rights under the Truth in Lending Act ( TILA ), specifically regarding her right to dispute and rescind certain debt-related obligations. 
On or about XX/XX/XXXX, Plaintiff sent written notice to Defendant, seeking to dispute and rescind the debt under 15 U.S.C. 1635 ( a ).

Despite receiving timely notice, Defendant refused to honor the dispute or correct the inaccuracies reported to the credit reporting agencies, in violation of TILA.

As a result of Defendants failure to comply, Plaintiff is entitled to rescind the alleged debt and seeks declaratory relief and damages for Defendants non-compliance with TILA. 
INACCURATE REPORTING Defendant inaccurately reported Plaintiffs payment history and debt status to credit reporting agencies, including [ specific reporting agencies, e.g., XXXX, XXXX, and XXXX ], reflecting charge-offs and delinquencies that did not accurately represent Plaintiffs payment history. 
Plaintiff disputed the inaccurate reporting with the credit reporting agencies, and despite these disputes, Defendant failed to correct the inaccuracies, in violation of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681.

As a result of Defendants inaccurate reporting, Plaintiff has suffered harm, including damage to her credit score, financial loss, and emotional distress.

CLAIMS FOR RELIEF COUNT 1 : VIOLATION OF THE TRUTH IN LENDING ACT ( TILA ), 15 U.S.C. 1635 Plaintiff realleges and incorporates by reference the preceding paragraphs. 
Defendant failed to provide the required disclosures under TILA, specifically regarding Plaintiffs right to dispute and rescind the debt-related obligations.

Plaintiff exercised the right to dispute and rescind by sending written notice within the statutory time period.

Defendants refusal to honor the rescission and correction constitutes a violation of 15 U.S.C. 1635.

Plaintiff seeks rescission of the alleged debt and a correction of all reports, along with statutory damages, attorneys fees, and costs.

COUNT 2 : VIOLATION OF THE FAIR CREDIT REPORTING ACT ( FCRA ), 15 U.S.C. 1681 Plaintiff realleges and incorporates by reference the preceding paragraphs.

Defendant reported inaccurate payment information to credit reporting agencies, causing harm to Plaintiffs credit score and financial standing.

Despite Plaintiffs dispute of these inaccuracies, Defendant failed to conduct a reasonable investigation or correct the reported information, in violation of FCRA, specifically 15 U.S.C. 1681i.

Plaintiff seeks damages for harm caused by the inaccurate reporting, including compensation for emotional distress, lost opportunities, and attorneys fees.

PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendant as follows : Rescission of the alleged debt under 15 U.S.C. 1635 ; Statutory damages and costs under TILA and FCRA ; An order requiring Defendant to correct the inaccurate information reported to credit reporting agencies ; Compensation for Plaintiffs emotional distress and financial damages ; Attorneys fees and costs ; Any other relief the Court deems just and proper.