Zakheim was collecting a debt for XXXX XXXX but it was settled years ago. They pulled my credit report without permission, and long after settlement. They told me on the phone that I have no other account with them. IT IS ILLEGAL FOR ZAKHEIM TO HAVE PULLED MY CREDIT REPORT WITHOUT PERMISSION ON XXXX/XXXX/XXXX. 


6. Defendant Zakheim & Lavrar, P.A. ( " Defendant '' ) is an entity duly licensed toconduct business in the state of Florida. 
7. Upon information and good-faith belief, Defendant 's principal place of businessis located at XXXX, FL XXXX. 
8. Defendant uses a means or facility of interstate commerce for the purpose offurnishing information to consumer reporting agencies. 
9. Defendant is a " person '' as defined by 15 U.S.C. 1681a ( b ). 
THE FAIR CREDIT REPORTING ACT10. The FCRA was enacted by Congress to ensure fair and accurate credit reporting, promote efficiency in the banking system, and to protect consumer privacy. See XXXX 
of XXXX, XXXX XXXX XXXX, XXXX ( XXXX ). 
11. To further purpose of protecting consumer privacy, the FCRA requires thatconsumer reporting agencies ( " CRA '' ) may only furnish a report regarding a consumer to aperson who has a " permissible purpose '' to use that consumer 's report. See 15 U.S.C. 
1681b ( a ) - ( b ). 
12. A permissible purpose exists where a person " intends to use the information inconnection with a credit transaction involving the consumer on whom the information is to befurnished and involving the extension of credit to ... the consumer. '' 15 U.S.C. 1681b ( a ) ( 3 ) ( A ). 
13. Obtaining a consumer report is colloquially known as " pulling '' a consumer'scredit report. 
14. In contrast to a " soft '' pull of an individual 's consumer report, which does notaffect the consumer 's credit score, " a 'hard pull ' involves accessing a credit report for thepurpose of issuing new credit or increasing the amount of existing credit. These inquiries can beXXXXseen by potential creditors and can impact a consumer 's credit score. '' XXXX, XXXX XXXX, XXXX XXXX XXXX XXXX ( XXXX XXXX. XXXX ) reconsideration denied, XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ). 
15. Thus, limiting access to consumer reports and prohibiting persons from obtainingconsumer reports without a permissible purpose not only promotes consumer privacy, but it alsopromotes congressional intent of promoting a fair credit reporting system, as it gives consumersa greater ability to manage their credit scores. 

FACTUAL ALLEGATIONS16. In an effort to collect an alleged debt, Defendant filed a state court action againstPlaintiff on XXXX XXXX, XXXX. 
17. On XXXX XXXX, XXXX, Plaintiff called Defendant and agreed to settle the debt over aperiod of six months. 
18. The account was settled in full on XXXX XXXX, XXXX. 
19. On XXXX XXXX, XXXX, Defendant filed a notice of voluntary dismissal withprejudice in the state court action. 
20. On XXXX XXXX, XXXX, Defendant requested and obtained a copy of Plaintiff'sExperian consumer report. 
21. Plaintiff did not provide Defendant with permission to access his consumer report. 
22. Upon information and belief, Defendant knowingly and intentionally obtainedPlaintiff 's consumer report. 
23. Upon information and belief, Defendant knowingly and willfully obtained aconsumer report for Plaintiff without a permissible basis. 
XXXXCOUNT I15 U.S.C. 1681b ( f ) ( 1 ) 24. Plaintiff repeats and re-alleges each and every allegation contained in paragraphsXXXX through XXXX and XXXX through XXXX. 
25. Defendant violated 15 U.S.C. 1681b ( f ) ( 1 ) by using or obtaining a consumerreport for any purpose unless the consumer report is obtained for a purpose for which theconsumer report is authorized to be furnished..