Product: Credit reporting or other personal consumer reports

see attachment for full complaint COUNT 1 : NEGLIGENT NONCOMPLIANCE UNDER FCRA 604 Claimant, XXXX XXXX, alleges as follows : 1. This cause of action arises under the Fair Credit Reporting Act ( FCRA ), specifically addressing negligent noncompliance with 15 U.S.C. 1681b ( a ) ( 2 ). 
2. On XX/XX/2023, Claimant applied for car financing with XXXX XXXX XXXX. The application was denied based on information obtained from a consumer report accessed by XXXX XXXX XXXX. 
3. The consumer report accessed by XXXX XXXX XXXX included information that violated Claimant 's rights under 15 U.S.C. 1681b ( a ) ( 2 ). 
4. Claimant had previously provided written instructions to XXXX and XXXX, explicitly directing them to delete specific items of information, especially details from furnishers who had previously violated Claimant 's rights to privacy, confidentiality, and the right to opt-out of information sharing with nonaffiliates. 
5. Respondents, including [ Credit Reporting Agency 's Name ], negligently failed to comply with Claimant 's written instructions, resulting in the inclusion of damaging negative items in the consumer report accessed by XXXX XXXX XXXX. 
6. Respondents ' negligent noncompliance led to inaccurate reporting, adversely affecting Claimant 's credit report and score, influencing XXXX XXXX XXXX denial of her financing application. 
WHEREFORE, Claimant, XXXX XXXX, demands XXXX, XXXX, and, if applicable, XXXX to each : 1. Cease furnishing consumer reports that do not comply with Claimant 's explicit written instructions. 
2. Provide compensation of {$1000.00} for damages.

3. Provide an additional {$1000.00} for emotional distress.

COUNT 2 : NEGLIGENT NONCOMPLIANCE UNDER FCRA 605 Claimant, XXXX XXXX, hereby asserts : 1. This cause of action arises under the Fair Credit Reporting Act ( FCRA ), specifically addressing violations of 15 U.S.C. 1681c.

2. FCRA 605 ( a ) ( 5 ) prohibits the inclusion of any adverse item of information in a consumer report, excluding records of convictions of crimes, which antedates the report by more than seven years.

3. FCRA 605 ( b ) outlines exempted cases where the provisions of 605 ( a ) are not applicable, including situations involving a credit transaction of {$150000.00} or more.

4. While in violation of Claimant 's written instructions, the credit reports provided to XXXX XXXX XXXX contained adverse items of information. 
5. The transaction for which the consumer reports were accessed involved a principal amount of less than {$150000.00}, rendering the exemption outlined in FCRA 605 ( b ) ( 1 ) inapplicable.

6. Credit reporting agencies, including [ Credit Reporting Agency 's Name ], violated FCRA 605 by providing XXXX XXXX XXXX XXXX consumer reports containing adverse items of information for a credit transaction of less than {$150000.00}. 
WHEREFORE, Claimant, XXXX XXXX, demands XXXX, XXXX, and, if applicable, XXXX to each : 1. Cease furnishing consumer reports that include adverse items of information for credit transactions involving a principal amount of less than 150,000.

2. Provide compensation of {$1000.00} for damages.

3. Provide an additional {$1000.00} for emotional distress.

COUNT 3 : NEGLIGENT NONCOMPLIANCE UNDER FCRA 619 Claimant, XXXX XXXX, asserts : 1. This cause of action is grounded in the Fair Credit Reporting Act ( FCRA ), particularly addressing violations of 15 U.S.C. 1681q.

2. FCRA 619 prohibits any person from knowingly and willfully obtaining information on a consumer from a consumer reporting agency under false pretenses.

3. Claimant previously sent an opt-out notice to Lexis Nexis, a consumer reporting agency, to prevent the sharing of her information with nonaffiliates.

4. Lexis Nexis fraudulently obtained Claimant 's information from creditors who had received her opt-out notice.

5. Claimant also explicitly opted out of the sharing of her information with affiliates, and XXXX is a subsidiary affiliate of Lexis Nexis. 
XXXX. XXXX, under the circumstances described, has knowingly and willfully obtained information on Claimant by false pretenses. 
XXXX. XXXX lacks express consent from Claimant to gather, assemble, and furnish credit reports in connection with any credit transaction she is involved in. 
WHEREFORE, Claimant, XXXX XXXX, demands XXXX to 1. Cease and desist the unauthorized obtaining and furnishing of information on Claimant.

2. Compensate the claimant {$1000.00} for damages.