Product: Credit reporting or other personal consumer reports

COMPLAINT INTRODUCTION Plaintiff XXXX XXXX brings this action against Defendant, Apple Card/GS Bank USA XXXX for violations of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., and the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 et seq. Plaintiff seeks redress for the Defendant 's inaccurate reporting of Plaintiffs payment history and for the unlawful furnishing of Plaintiffs information to third-party vendors without proper authorization.

This action arises out of Apple Card/GS Bank USAs negligent and willful failure to ensure accurate reporting to consumer reporting agencies and their use of third-party vendors to disseminate Plaintiff 's sensitive personal information in violation of federal law.

JURISDICTION AND VENUE This Court has jurisdiction over this matter pursuant to 28 U.S.C. 1331, as the claims involve violations of federal law, including the Fair Credit Reporting Act and Fair Debt Collection Practices Act. 
Venue is proper in this district pursuant to 28 U.S.C. 1391 ( b ) because the Plaintiff resides in this judicial district and the acts that gave rise to this action occurred within this district. 




PARTIES Plaintiff, XXXX XXXX, is a natural person residing at XXXX XXXX XXXX XXXX XXXX XXXX XXXX and is a consumer as defined by 15 U.S.C. 1681a ( c ). Plaintiffs date of birth is XX/XX/year>. 
Defendant, Apple Card/GS Bank USA XXXX XXXX a corporation engaged in the business of extending credit and furnishing information to consumer reporting agencies, and is headquartered in New York XXXX New York XXXX 
FACTUAL ALLEGATIONS Plaintiff has a credit account with Apple Card/GS Bank USA , Account No. [ Insert Account Number ], and Apple Card/GS Bank USA has been furnishing information about Plaintiff 's account to credit reporting agencies including XXXX, XXXX, and XXXX. 
Beginning in or around [ Insert Date ], Plaintiff discovered that Apple Card/GS Bank USA had furnished inaccurate information about Plaintiffs payment history to these reporting agencies. Specifically, Apple Card/GS Bank USA inaccurately reported Plaintiff 's payment status as " charged off '' and delinquent, despite errors in reporting the correct date of first delinquency and last payment, which Plaintiff had previously disputed in writing. 
Plaintiff disputed the inaccuracies with Apple Card/GS Bank USA and the credit reporting agencies, but Apple Card/GS Bank USA failed to conduct a reasonable investigation or correct the inaccuracies. As a result, Plaintiffs consumer report reflects inaccurate and damaging information. 
CLAIM I ( Violation of the Fair Credit Reporting Act, 15 U.S.C. 1681s-2 ( b ) ) Plaintiff re-alleges and incorporates by reference all preceding paragraphs.

Under 15 U.S.C. 1681s-2 ( b ), Apple Card/GS Bank USA , as a furnisher of credit information, is required to conduct a reasonable investigation when a consumer disputes the accuracy of information reported to consumer reporting agencies. 
Plaintiff notified the credit reporting agencies of the dispute, and these agencies, in turn, notified Apple Card/GS Bank USA of the dispute. However, Apple Card/GS Bank USA failed to conduct a reasonable investigation or correct the inaccurate information.

Apple Card/GS Bank USAs failure to conduct a proper investigation and correct the inaccuracies has caused Plaintiff to suffer damages, including but not limited to denial of credit, emotional distress, and harm to Plaintiff 's creditworthiness. 
CLAIM II ( Violation of the Fair Debt Collection Practices Act, 15 U.S.C. 1692c ( b ) ) Plaintiff re-alleges and incorporates by reference all preceding paragraphs.

Under 15 U.S.C. 1692c ( b ), a debt collector may not communicate with third parties in connection with the collection of a debt without the consumer 's consent.

Apple Card/GS Bank USA communicated Plaintiffs personal and account information, including his debt status, to third-party vendors responsible for preparing and sending collection notices without Plaintiffs consent or knowledge , thereby violating Plaintiff 's rights under 15 U.S.C. 1692c ( b ). 
Plaintiff suffered concrete harm as a result of the disclosure of sensitive financial information to third parties, including emotional distress and invasion of privacy. 
DAMAGES As a direct result of Apple Card/GS Bank USA 's violations of 15 U.S.C. 1681s-2 ( b ) and 15 U.S.C. 1692c ( b ), Plaintiff has suffered actual damages, including harm to credit reputation, denial of credit opportunities, emotional distress, and other damages to be proven at trial. 

PRAYER FOR RELIEF WHEREFORE, Plaintiff XXXX XXXX prays for judgment against Defendant Apple Card/GS Bank USA as follows : Statutory damages under the FCRA, 15 U.S.C. 1681n ( a ) ( 1 ), and actual damages for the negligent and willful reporting of inaccurate credit information ; Statutory damages under the FDCPA, 15 U.S.C. 1692k ; Punitive damages for the willful violations of the FCRA ; Reasonable attorney 's fees and costs incurred in bringing this action ; Any further relief that this Court deems just and proper.

JURY DEMAND Plaintiff demands a trial by jury on all issues so triable.