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

LexisNexis has violated the following : 1. 15 USC 1681 ( a ) ( 4 ) " Infringed Upon a Consumer 's right to privacy '' and 2. 15 USC 1681b ( a ) ( 2 ) No Permissible purpose/ No written instruction I had recently received notification from a customer service representative from XXXX XXXX my insurance rate has increased ; when I inquired about the increase in my insurance premiums, the rep advised that it was due to a report obtained from Lexis Nexis and a ticket that I received. I am still waiting for the case to reset the alleged ticket issued due to the request for reasonable accommodations based on my XXXX ( See attachments from the courts ). Therefore, the Information obtained is inaccurate and fraudulent at best. Accordingly, I REQUEST THE FRAUDULENT INFORMATION THAT IS BEING REPORTED TO BE REMOVED EFFECTIVE IMMEDIATELY BEFORE A LAWSUIT IS FILED AGAINST LexisNexis. I HAVE ATTACHED INFORMATION FROM THE COURTS, U.S. Department of Justice, and XXXX. DELETE THE INFORMATION FROM LEXISNEXIS. 

violations of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681, et seq., as amended.

II.

JURISDICTION AND VENUE 2. Jurisdiction of this Court arises under 15 U.S.C. 1681p and 28 U.S.C. 1331.

3. Venue lies properly in this district pursuant to 28 U.S.C. 1391 ( b ).

III.

PARTIES 4. Plaintiff is an adult individual who resides in TX. 5.
Defendant XXXX XXXX XXXX XXXX XXXX. ( XXXX ) is a business entity and consumer reporting agency that regularly conducts business in the Central District of California, and which has its headquarters and a principal place of business located at XXXX XXXX XXXX XXXX XXXX, CA XXXX. 
6. Defendant LexisNexis Risk XXXX XXXX XXXX LLC ( Lexis ) is a business entity that provides background screening services, decision-making intelligence and operates as a consumer reporting agency and furnisher of credit information. Lexis regularly conducts business in XXXX XXXXXXXX XXXX XXXX California has a principal place of business at XXXX XXXX XXXX, XXXX, GA, XXXX. 
IV.

FACTUAL ALLEGATIONS 7. Defendants have been reporting derogatory and inaccurate statements and information relating to Plaintiff and Plaintiffs credit history to third parties ( inaccurate information ). 
8. The inaccurate information includes, but is not limited to : three ( 3 ) Federal tax liens that should not be reporting on Plaintiffs personal credit files or reports, which do not belong to the Plaintiff. 
9. The inaccurate information reporting on Plaintiffs credit reports is not directly derived from government records or court dockets. The original supplier of this inaccurate information to XXXX was Lexis, or Lexis corporate predecessor and/or its contractors. Lexis or its corporate predecessor, through its contractors, obtains select information from court and government records, not the complete or actual public records, and then molds and fabricates that select information into the format which it sells to XXXX and other third parties to be placed upon consumer credit reports. 
10. As evident in the IRS records from the operative years, Plaintiff is not personally liable for these Federal tax liens, and that they are clearly not entered against her. IRS records confirm that her tax liability is {$0.00} and that she has no tax liens filed against her. 
11. Nevertheless, XXXX is reporting the Federal tax liens on the personal credit files and reports of Plaintiff. 
12. Lexis continues to report inaccurate information, as it has not updated the select information that it compiles and sells about the Plaintiff, and it instead continues to inaccurately report and verify the Federal tax liens incurred by a business entity on Plaintiffs personal credit reports to XXXX and/or other third parties. 
13. Plaintiff has disputed the inaccurate information on at least two occasions with XXXX, by following Experians established procedures for disputing consumer credit information, beginning in or around XX/XX/2010. 
14. Further, Lexis, as the original supplier and as a credit furnisher of this information, was advised of Plaintiffs disputes through XXXX. Despite these disputes, Lexis failed to investigate and correct the inaccurate Federal tax liens within 30 days as required by the FCRA. To the contrary, both Lexis and XXXX verified as purportedly accurate the Federal tax liens and left them on Plaintiffs credit reports. 
15. Notwithstanding Plaintiffs efforts, XXXX has sent Plaintiff correspondence indicating its intent to continue publishing the inaccurate information and XXXX continues to publish and disseminate such inaccurate information to other third parties, persons, entities and credit grantors. XXXX has repeatedly published and disseminated consumer reports to such third parties from at least XX/XX/2010 through the present. 
16. The inaccurate information negatively reflects upon the Plaintiff, Plaintiffs credit repayment history, Plaintiffs financial responsibility as a taxpayer and XXXX creditworthiness. 
17. Defendants have been reporting the inaccurate information through the issuance of false and inaccurate credit information and consumer reports that they have disseminated and resold to various persons, both known and unknown. 
18. Despite Plaintiffs efforts, Defendants have never : ( 1 ) contacted Plaintiff to follow up on, verify and/or elicit more specific information about Plaintiffs disputes ; ( 2 ) contacted any third parties that would have relevant information concerning Plaintiffs disputes ; or ( 3 ) forwarded all relevant information concerning Plaintiffs disputes to the entities originally furnishing the inaccurate information. 
19. Despite Plaintiffs exhaustive efforts to date, Defendants have nonetheless deliberately, willfully, intentionally, recklessly and negligently repeatedly failed to perform reasonable investigations and/or reinvestigations of the above disputes as required by the FCRA, failed to remove the inaccurate information, failed to report on the results of their investigations and/or reinvestigations to all credit reporting agencies and continued to report the derogatory inaccurate information about Plaintiff.

20. As of result of Defendants conduct, Plaintiff has suffered actual damages in the form of lost credit opportunities, harm to credit reputation and credit score, and emotional distress, including humiliation and embarrassment. 
21. At all times pertinent hereto, Defendants were acting by and through their agents, servants and/or employees who were acting within the course and scope of their agency or employment, and under the direct supervision and control of the Defendants herein.

22. At all time
s pertinent hereto, the conduct of the Defendants, as well as that of their agents, servants and/or employees, was malicious, intentional, willful, reckless, and in grossly negligent disregard for federal and the rights of the Plaintiff herein.

V. 
FIRST CLAIM FOR RELIEF Experians Violations of the FCRA 23. Plaintiff incorporates the foregoing paragraphs as though the same were set forth at length herein. 
24. At all times pertinent hereto, Experian was a person and consumer reporting agency as those terms are defined by 15 U.S.C. 1681a ( b ) and ( f ). 
25. At all times pertinent hereto, the Plaintiff was a consumer as that term is defined by 15 U.S.C. 
1681a ( c ). 
26. At all times pertinent hereto, the above-mentioned credit reports were consumer reports as that term is defined by 15 U.S.C. 1681a ( d ). 
27. Pursuant to 15 U.S.C. 1681n and 15 U.S.C. 1681o, XXXX is liable to the Plaintiff for willfully and negligently failing to comply with the requirements of 15 U.S.C. 1681e ( b ) and 1681i.

28. The conduct of Experian was a direct and proximate cause, as well as a substantial factor, in bringing about the serious injuries, actual damages and harm to the Plaintiff that are outlined more fully above and, as a result, XXXX is liable to the Plaintiff for the full amount of statutory, actual and punitive damages, along with the attorneys fees and the costs of litigation, as well as such further relief, as may be permitted by law.

VI. 
SECOND CLAIM FOR RELIEF Lexis Violations of the FCRA 29. Plaintiff incorporates the foregoing paragraphs as though the same were set forth at length herein.

30. At all times pertinent hereto, Lexis was a person and a consumer reporting agency as those terms are defined by 15 U.S.C. 1681a ( b ) and ( f ), and also a furnisher of credit information. 
31. At all times pertinent hereto, Plaintiff was a consumer as that term is defined by 15 U.S.C.

1681a ( c ). 
32. At all times pertinent hereto, the above-mentioned credit reports were consumer reports as that 33. Pursuant to 15 U.S.C. 1681n and 15 U.S.C. 1681o, Lexis is liable to the Plaintiff for willfully and negligently failing to comply with the requirements of 15 U.S.C. 1681i ; 15 U.S.C. 1681e ( b ), and 15 U.S.C. 1681s-2 ( b ). 
34. The conduct of Lexis was a direct and proximate cause, as well as a substantial factor, in bringing about the serious injuries, actual damages and harm to the Plaintiff that are outlined more fully above and, as a result, Lexis is liable to the Plaintiff for the full amount of statutory, actual and punitive damages, along with the attorneys fees and the costs of litigation, as well as such further relief, as may be permitted by law.

VII.

JURY TRIAL DEMAND 35. Plaintiff demands trial by jury on all issues so triable.

VIII. 
PRAYER FOR RELIEF WHEREFORE, Plaintiff seeks judgment in Plaintiffs favor and damages against the Defendants, based on the following requested relief : ( a ) Actual damages ; ( b ) Statutory damages ; ( c ) Punitive damages ; ( d ) Costs and reasonable attorneys fees pursuant to 15 U.S.C.

1681n and 1681o ; and ( e ) Such other and further relief as may be necessary, just and proper.