Product: Credit reporting or other personal consumer reports

I am submitting this complaint regarding Accounts : 1 ) XXXX XXXX Account Number XXXX XXXX XXXX XXXX ending in XXXX XXXX XXXX XXXX ending in XXXX XXXX XXXX XXXX XXXX ending in XXXX Business Line of Credit ( BLOC ) ending in XXXX XXXX XXXX XXXX XXXX ending in XXXX XXXX XXXX XXXX  account ending in XXXX XXXX XXXX XXXX account ending in XXXX Re : Complaint for Violations of the Fair Credit Reporting Act ( 15 U.S.C. 1681 et seq. ), Right to Privacy, New York General Business Law 349, and Racketeer Influenced and Corrupt Organizations Act ( RICO ) I. Introduction : A System of Extortion into Usury, Threatening Small Businesses and the Public This case exposes how financial institutions exploit small businesses through coordinated financial manipulation, driving entrepreneurs into high-interest debt that borders on usury. The Defendants malicious reporting of five corporate credit cards as charge-offs on my personal credit report, despite years of on-time payments and without my consent, alongside the cancellation of two personal credit cards held in perfect standing for over ten years, illustrates willful misconduct. These actions were not merely punitivethey reflect a sinister strategy designed to create financial crises for small businesses, forcing them into predatory loans with interest rates of up to 300 % a legalized form of usury enabled through Dodd-Frank loopholes. 

This racket functions much like organized crime : By severing access to traditional credit, the Defendants compelled my businessand many othersinto relying on high-interest Merchant Cash Advances ( MCAs ). These exorbitant loans extract wealth through relentless fees and interest, leaving businesses trapped in a cycle of debt. Banks and financial institutions profit twice : first by denying businesses affordable credit and second by controlling or partnering with loan firms offering MCAs, ensuring they capture profits from both ends of this manufactured crisis. 

This scheme not only affects businesses like mine but undermines the broader economy by eliminating competition, driving up prices, and forcing layoffs. As businesses struggle to survive under the weight of usurious debt, they must raise prices, reduce services, and cut jobs, creating inflationary pressure that hurts workers and consumers alike. This inflation is falsely blamed on external economic forces, but it is the direct result of deliberate manipulation by financial institutions, much like the mortgage crisis of XXXX. Back then, banks profited from reckless lending and came out stronger, only to introduce even more dangerous practices. Left unchecked, these usury-based schemes will push the economy toward another collapse, with small businesses and working-class employees once again bearing the brunt of the fallout. 

The Defendants actions reflect this malicious trend : The loss of {$750000.00} in credit lines forced me to rely on high-interest debt, which compounded the damage. Vendors withdrew credit terms, and I lost {$1.00} XXXX in clients and employees, severely disrupting my ability to operate. These actions are not just private disputesthey represent a systemic attack on small businesses and their role in the marketplace, as recognized in XXXX XXXX  ' XXXX  XXXX XXXX  XXXX  XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ). The court in XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) also found that deceptive practices that harm vendors and business relationships fall under XXXX XXXX, and XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX ) affirmed that harm to employees and vendors from deceptive conduct warrants legal intervention. 

This court must act to prevent further exploitation of small businesses and workers. The Defendants practicesextortion disguised as usurynot only threaten individual entrepreneurs but destabilize communities and drive inflation, creating a dangerous precedent that will devastate the marketplace if left unchecked. 

The Defendants actions align with collusive and exclusionary behavior seen in landmark cases such as XXXX XXXX XXXX XXXX  and XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, which established that deceptive practices affecting credit are actionable under New York General Business Law ( GBL 349 ). Moreover, the defendants ' coordinated efforts may constitute RICO violations under federal law, as illustrated by XXXX v. United States and XXXX v. United States, where informal collaboration for fraudulent purposes led to liability. The systematic actions by these entities reflect a deliberate effort to leverage power over credit availability, forcing small businesses into financial dependency on high-interest products controlled by the very institutions that restricted traditional credit access. 

The acquisition of XXXX XXXX by XXXX XXXX, as well as their collaboration with XXXX XXXX XXXX  and XXXX, further demonstrates the level of coordination. XXXX XXXX XXXX  provides the infrastructure for these loans, while XXXX and XXXX market high-interest products that are directly tied to the credit restrictions imposed by XXXX XXXX . This coordination and collusion benefit the defendants at every level, from credit manipulation to profiting through high-interest loansresulting in violations actionable under RICO. 

II. Jurisdiction and Venue Federal Jurisdiction : This Court has jurisdiction under the Fair Credit Reporting Act ( 15 U.S.C. 1681p ) for federal claims and RICO ( 18 U.S.C. 1964 ).

Supplemental Jurisdiction : The Court has jurisdiction under 28 U.S.C. 1367 for related state law claims under GBL 349.

Venue : Venue is proper in this district because the defendants ' actions and resulting harm occurred within this jurisdiction. 

III. Factual Background Improper Credit Reporting and Coercion into High-Interest Loans The defendants reported five corporate credit cards on my personal credit report without my consent, negatively impacting my credit score despite my years of timely payments. They canceled these corporate cards without warning, which coincided with the cancellation of two personal cards that I had maintained in perfect standing for over ten years. This sudden action left me with no access to traditional credit. 

Following the cancellation of these credit cards, I was subjected to persistent outreach from XXXX, which led me to take two high-interest loans under extreme financial duress. These loans were positioned as the only viable alternative after the defendants eliminated other credit lines. 

XXXX and XXXX XXXX XXXX Relationship XXXX XXXX acquired XXXX XXXX in XXXX, expanding its reach into small business lending by integrating XXXX 's XXXX XXXX, which offers working capital products similar to Merchant Cash Advances ( MCAs ). XXXX  loans are issued directly through XXXX XXXX XXXX XXXX. 

XXXX XXXX XXXX, a partner of XXXX XXXX, was used to provide infrastructure for issuing loans, indicating a coordinated effort between these entities to leverage restricted credit access and funnel borrowers into high-cost alternatives. 

Public Harm and Economic Consequences The defendants ' practices harmed not only me but also my employees and vendors, resulting in {$1.00} XXXX in lost business and impairing my ability to hire or retain talent. These practices have broader public consequences, including increased market costs and inflationary pressure, as small businesses are forced into unsustainable debt cycles, which limit growth and drive prices higher. This artificial inflation, fueled by the defendants ' coordinated practices, forces struggling businesses to pass on costs to consumers, exacerbating economic inequality and creating a cycle of debt and instability. 

Shared Corporate Connections and Suspicious Practices Investigations into business records reveal that XXXX and XXXX  share financial infrastructure and connections through XXXX, suggesting a coordinated effort to leverage restricted credit into profit through high-interest lending products. The Georgia, Delaware, and California business registries, along with OpenCorporates data, confirm overlapping officers, agents, and financial relationships, supporting the claims of collusion. 

IV. Legal Claims Count I : Violations of the Fair Credit Reporting Act ( 15 U.S.C. 1681 et seq. ) Violation of 15 U.S.C. 1681b Impermissible Use and Disclosure of Credit Information Defendants improperly reported corporate accounts on my personal credit report, without consent or permissible purpose. 

Violation of 15 U.S.C. 1681e ( b ) Inaccurate Reporting Practices Selective reporting of negative information without reflecting positive payment history misled creditors and lenders, harming my financial standing.

Count II : Violations of New York General Business Law 349 Deceptive and Unfair Practices Defendants engaged in deceptive practices by manipulating credit availability to coerce borrowers into unfavorable, high-interest loans. 

Consumer-Oriented Impact and Public Harm The deceptive conduct harmed my business and employees, and had broader economic effects, as evidenced by the cases of XXXX XXXX  XXXX XXXX XXXX XXXX XXXX  and XXXX, both of which establish the defendants ' actions as consumer-oriented misconduct affecting the public. 

Count III : Violations of the Racketeer Influenced and Corrupt Organizations Act ( RICO ) Collusion and Conspiracy Defendants acted in concert to manipulate credit availability and profit through coercion. This behavior aligns with XXXX v. United States and XXXX v. United States, establishing that informal coordination for fraudulent purposes constitutes a RICO enterprise.

V. Damages Sought Actual Damages : {$750000.00} in lost credit lines. 

{$100000.00} in excess interest due to high-cost loans. 

{$1.00} XXXX in lost business revenue. 

Emotional Distress Damages : {$150000.00} for the emotional hardship caused by financial instability. 

Statutory and Punitive Damages : Under FCRA and GBL 349, totaling {$42.00} XXXX. 

Attorneys Fees and Costs : Recovery of all legal fees and costs. 

VI. Prayer for Relief WHEREFORE, the Plaintiff respectfully requests judgment as follows : Awarding all damages as outlined above. 

Granting treble damages under RICO and GBL 349.

Granting any other relief deemed just.

VII. Jury Demand The Plaintiff demands a trial by jury on all issues so triable. 



This will be filed on behalf of the genocide of mainstreet and small business. Class action suit.