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

1. Plaintiff is an individual consumer who resides in XXXX, CO. 

2. Defendants XXXX XXXX XXXX ( " XXXX '' ) is a Foreign Corporation doing business in Colorado through its registered offices in XXXX Colorado, XXXX County, Colorado. At all times relevant to this complaint, it is a " consumer reporting agency '' as defined by the FCRA at 15.U.S.C. 1681a ( f ). 

3. Defendants XXXX XXXX XXXX  ( " Trans '' ) is a Foreign Corporation doing business in Colorado through its registered offices in XXXX, Colorado, XXXX County, Colorado. At all times relevant to this complaint, it is a " consumer reporting agency '' as defined by the FCRA at 15.U.S.C. 1681a ( f ). 

4. Defendants XXXX  XXXX, ( " XXXX '' ) is a Foreign Corporation doing business in Colorado through its registered offices in XXXX, Colorado, XXXX County, Colorado. At all times relevant to this complaint, it is a " consumer reporting agency '' as defined by the FCRA at 15.U.S.C. 1681a ( f ). 

5. Defendant XXXX XXXX XXXX XXXX , XXXX., ( XXXX ) is a Nevada Corporation located at XXXX XXXX XXXX XXXX, XXXX, CO XXXX United States. 

6. Consumer has repeatedly disputed the inaccurate information with the Defendants, by both oral and written communications to their representatives and by following XXXX, established procedure for disputing consumer credit information. 

7. Defendants have repeatedly published and disseminated consumer reports to such third parties, including but limited to, XXXX. 

8. Despite Consumers efforts, Defendants, have never : a ) contacted the Consumer to follow up on, verify and/or elicit more specific information about Consumers disputes ; b ) contacted any third parties that would have relevant information concerning Consumers disputes ; c ) forwarded any relevant information concerning Consumers disputes to the entities originally furnishing the inaccurate information ; d ) requested or obtained any credit applications, or other relevant documents from the entities furnishing the inaccurate information ; and e ) performed any handwriting analysis. 

9. On information and belief, Defendants notified Defendant XXXX of Plaintiffs disputes through e-Oscar system by sending an ACDV form. 

10. Defendants willfully and negligently violated the FCRA, 15 U.S.C. 1681i by failing to perform a reasonable reinvestigation into Plaintiffs disputes, failing to forward all relevant information to the furnisher, parroting the furnisher, and failing to notify Plaintiff of the results of the disputes. 

11. Defendant also violated FCRA, 15 U.S.C. 1681g by failing to provide Plaintiff with a copy of his credit file upon request, Plaintiff requested a copy from XXXX  on XX/XX/2018, and has yet to receive a copy. 

12. Defendants XXXX willfully and negligently violated 15 U.S.C. 1681s-2 (  b ) by failing to perform a reasonable investigation into Plaintiff disputes, which would have included reviewing and considering that XXXX did not have Plaintiffs signature on any documents, that XXXX had illegally reported accounts in Plaintiffs name without her knowledge or consent and that Plaintiff had multiple direct conversations with Defendants XXXX and about this fraud. 

13. Defendants, when preforming its investigations into Plaintiff disputes, employed superficial faux-investigations, which consisted of essential matching the inaccurate data previously reported with inaccurate data currently in its system. 

14. Defendants also should have responded to the CRAs that the account could not be verified because XXXX did not have Plaintiffs signature on file. 

15. Lastly, XXXX failed to report to the credit reporting agencies that Plaintiff disputed the debt, which was inaccurate and misleading, and negatively affected Plaintiffs credit score because disputed tradelines are not taken into consideration in some credit scoring models. 

16. The Defendants violations of the FCRA caused the Plaintiff actual damages, including harm to credit score, emotional distress, and inconvenience.