1

Filed 8/20/18

IN THE SUPREME COURT OF CALIFORNIA

EILEEN CONNOR, )

)

Plaintiff and Appellant, )

) S229428

v. )

) Ct.App. 2/4 B256075

FIRST STUDENT, INC., et al., )

) Los Angeles County

Defendants and Respondents. ) Super. Ct. No. JCCP4624

____________________________________)

We granted review to resolve a conflict in the Courts of Appeal over 

whether the Investigative Consumer Reporting Agencies Act (ICRAA) (Civ. 

Code, § 1786 et seq.)1 is unconstitutionally vague, in violation of due process, as 

applied to employer background checks because it overlaps, in part, with the 

Consumer Credit Reporting Agencies Act (CCRAA) (§ 1785.1 et seq.). We agree 

with the Court of Appeal that some overlap between the two statutes does not 

render ICRAA unconstitutionally vague when the statutes are otherwise 

unambiguous. We therefore affirm the Court of Appeal judgment. 

FACTS AND PROCEDURAL HISTORY

Current and former bus drivers filed this class action against their 

employers, defendants First Student, Inc., and First Transit, Inc. (collectively 

First), and HireRight Solutions, Inc., and HireRight, Inc. (collectively HireRight), 

the investigative consumer reporting agencies that conducted background checks 

 

1 All further statutory references are to the Civil Code unless otherwise 

indicated. 
2

on them. Connor is the selected bellwether plaintiff for the operative consolidated 

fourth amended complaint.2 

Connor worked as a school bus driver for Laidlaw Education Services, 

which First acquired in October 2007. First requested that consumer reporting 

agency USIS (HireRight’s corporate predecessor) conduct background checks on 

its employees on three separate occasions in 2007, 2009, and 2010. The 

background reports elicited information about the employees, including criminal 

records, sex offender registries, address history, driving records, and employment 

history. First “admits that those background checks [would be] used to confirm 

that Connor and the other employees ‘are properly qualified to safely perform their 

job duties.’ ” 

Before conducting the background checks, First sent Connor a “Safety 

Packet” booklet. The booklet included a notice, entitled “Investigative Consumer 

Report Disclosure and Release,” that authorized USIS to prepare a consumer 

report or investigative consumer report. The notice provided that Connor could 

view the file maintained on her, receive a summary of that file by telephone, or 

obtain a copy of it. The notice also explained that Connor could request an 

“investigative consumer report” that included “ ‘names and dates of previous 

employers, reason for termination of employment, work experience, accidents, 

academic history, professional credentials, drugs/alcohol use, [and] information 

 

2 The 1,200 plaintiffs in the coordinated cases make identical claims. The 

operative complaint for all plaintiffs is the consolidated fourth amended complaint 

in which Connor and another plaintiff, Jose Gonzalez, were appointed as 

bellwether plaintiffs. First filed a motion for summary judgment against Connor, 

and HireRight filed a motion for summary judgment against Gonzalez. The trial 

court granted both motions for First, and both Connor and Gonzalez filed a notice 

of appeal. The Court of Appeal consolidated the appeals, but later vacated its 

consolidation order as to Gonzalez’s appeal when HireRight filed a petition for 

bankruptcy. This appeal concerns First’s judgment against Connor only.
3

relating to [the employee’s] character . . . which may reflect upon [her] potential 

for employment.’ ” The notice included a check box that generally described 

Connor’s rights under ICRAA and informed her that she could check the box if 

she wanted to receive a copy of the report. (See § 1786.16, subd. (b)(1).) It also 

informed her that checking the box would release First from all claims and 

damages arising out of or relating to its background investigation. Connor’s 

lawsuit alleges that the notice did not satisfy the ICRAA’s specific requirements 

and that First failed to obtain her written authorization to conduct the background 

check, as ICRAA requires. (§ 1786.16, subd. (a)(2)(C) [consumer subject to 

ICRAA must authorize “in writing the procurement of the report”].) Written 

authorization ensures that the subjects of the investigation are aware of their right 

to receive copies of the information gathered about them so they can correct 

inaccuracies, dispute the information, and request reinvestigation. (§ 1786.2 et 

seq.) 

Connor sued First for violating ICRAA because its 2010 notice did not 

satisfy ICRAA notice requirements and First did not obtain her written 

authorization to conduct the background investigation.3 (See § 1786.16, subd. 

(a)(2)(C).) “First admit[ted] that the background checks it requested HireRight to 

prepare included reports containing information regarding the subject’s criminal 

records, sex offender status, address history, driving records, and employment 

history.” It moved for summary judgment, however, claiming that ICRAA is 

unconstitutionally vague as applied to Connor’s claim because it overlaps with 

 

3 A subgroup of plaintiffs who were terminated after employers conducted 

posthiring background checks sought injunctive relief under the Unfair 

Competition Law (Bus. & Prof. Code, § 17200 et seq.) (UCL). The UCL claim is 

predicated on proof of the ICRAA violation, however. 
4

CCRAA and that, in any event, First’s notice satisfied CCRAA. The trial court 

granted First’s motion.

The Court of Appeal reversed the trial court’s judgment, finding that 

although ICRAA and CCRAA might overlap to some degree, there is no “positive 

repugnancy” between them that would render ICRAA unconstitutional. The court 

held that agencies that provide reports (including reports prepared for employers 

addressing employee creditworthiness and character) “can comply with each act 

without violating the other.” We granted First’s petition for review. 

DISCUSSION

I. Statutory Background

In 1970, the Legislature enacted the Consumer Credit Reporting Act. (Civ. 

Code, former § 1785.1 et seq., added by Stats. 1970, ch. 1348, § 1, p. 2512 and 

repeated by Stats. 1975, ch. 1271, § 2, p. 3377.) The act governed “credit rating 

reports” that included consumer credit record and standing reports. That same 

year, Congress passed the Fair Credit Reporting Act (FCRA). (15 U.S.C. § 1681 

et seq.) FCRA defined a “consumer report” to include an individual’s “credit 

worthiness, credit standing, credit capacity, character, general reputation, personal 

characteristics, or mode of living.” (15 U.S.C. § 1681a(d)(1).) FCRA 

distinguished between consumer reports that contained information obtained by 

personal interviews, and consumer reports that were gathered by other means. 

(Id., § 1681a(e).) 

In 1975, our Legislature repealed the 1970 Consumer Credit Reporting Act 

and enacted ICRAA and CCRAA to govern consumer background reports, 

including checks conducted for employment purposes. (§§ 1786 et seq., 1785.1 et 

seq.) The statutes were modeled after FCRA and were intended to serve 

complementary, but not identical, goals. Both ICRAA and CCRAA had similar 

purposes. They were enacted to ensure that consumer reporting agencies “exercise 
5

their grave responsibilities with fairness, impartiality, and a respect for the 

consumer’s right to privacy.” (§§ 1785.1, subd. (c), 1786, subd. (b).) As 

originally enacted, ICRAA applied to consumer reports that included character 

information obtained only through personal interviews. (Stats. 1975, ch. 1272, 

§ 1, p. 3378.) The statute was, in part, designed to protect consumers from 

identity theft by giving them “copies of any investigative consumer reports made 

on them.” (§ 1786, subd. (e).) 

ICRAA states that “[a]n investigative consumer reporting agency” may 

provide an “investigative consumer report” to a person other than the subject of 

the report under limited circumstances. (§ 1786.12.) Such a report can be given to 

a person who “[i]ntends to use the information for employment purposes.” (Id., 

subd. (d)(1).) As the Court of Appeal observed, the statute defines an 

“investigative consumer report” as one “in which information on a consumer’s 

character, general reputation, personal characteristics, or mode of living is 

obtained through any means.” (§ 1786.2, subd. (c).) 

ICRAA requires the person procuring the report (or causing it to be made) 

for employment purposes “other than suspicion of wrongdoing or misconduct by 

the subject of the investigation” (§ 1786.16, subd. (a)(2)), to “certify to the

investigating consumer reporting agency” (id., subd. (a)(4)) that it provided the 

consumer a “clear and conspicuous disclosure in writing” (id., subd. (a)(2)(B)) that 

includes the act’s disclosure requirements, and that the consumer gave a written 

authorization for the report’s procurement. In the event the recipient of an 

investigative report takes an adverse employment action against the consumer 

based on information in the report, the person taking the action must provide the 

consumer with the name and address of the investigative consumer agency that 

supplied that report. (§ 1786.40, subd. (a).) 
6

Until 1998, consumer reports were classified under CCRAA or ICRAA, 

depending largely on the means used to collect the information in those reports. In 

pertinent part, CCRAA defined “consumer credit report” to include “any written, 

oral, or other communication of any information by a consumer reporting agency 

bearing on a consumer’s credit worthiness, credit standing, or credit capacity, 

which is used or is expected to be used . . . for . . . employment purposes.” 

(Former § 1785.3, subd. (c).)4 That definition excluded “any report containing 

information solely on a consumer’s character, general reputation, personal 

characteristics, or mode of living which is obtained through personal interviews

with neighbors, friends, or associates of the consumer reported on, or others with 

whom he is acquainted or who may have knowledge concerning any such items of 

information.” (Ibid., italics added.) Thus, certain reports containing information 

gathered through personal interviews were subject to ICRAA only. But both 

statutes governed reports that contained information relating to character and 

creditworthiness, based on public information and personal interviews that were 

used for employment background purposes. 

Congress expanded FCRA in 1996 to enhance consumer privacy 

protections. (Omnibus Consolidated Appropriations Act of 1997 (Pub.L. No. 104-

208 (Sept. 30, 1996) 110 Stat. 3009, 426-462).5 Two years later, our Legislature 

 

4 This language is still present in the current version of CCRAA. (§ 1785.3, 

subd. (c).) 

5 The amendments to FCRA “were designed to better ensure the accuracy 

and privacy of the information contained in consumer or credit reports.” (Fed. 

Trade Com., Privacy, Accuracy and Fairness of Sensitive Personal Information 

Enhanced for Consumers Under Amended Credit Reporting Statute (Sept. 29, 

1997) <http://www.ftc.gov/news-events/press-releases/1997/09/privacy-accuracyand-fairness-sensitive-personal-information> (as of Aug. 15 2018). All Internet 

citations in this opinion are archived by year, docket number, and case name at 

<http://www.courts.ca.gov/38324.htm>.
7

amended ICRAA to eliminate the personal interview limitation and expand the 

statute’s scope to include character information obtained under CCRAA or 

“obtained through any means.” (Stats. 1998, ch. 988, § 1, p. 7549.)6 The 

amendment was a response to the sheer volume of employers using background 

checks to prescreen applicants, and was intended to promote disclosure and 

accuracy in background checks, especially in the rental, employment, and 

insurance contexts. (See Sen. Com. on Judiciary, Analysis of Sen. Bill No. 1454 

(1997-1998 Reg. Sess.) as amended Apr. 27, 1998, p. 4.) After the amendment, 

CCRAA continues to govern consumer reports that include character information 

obtained from a source other than personal interviews, as long as those reports 

contain information “bearing on a consumer’s credit worthiness, credit standing, 

or credit capacity.” (§ 1785.3, subd. (c).) 

II. Alleged Vagueness Issues

It is a well-settled rule that “a statute which either forbids or requires the 

doing of an act in terms so vague that [people] of common intelligence must 

necessarily guess at its meaning and differ as to its application, violates the first 

essential of due process of law.” (Connally v. General Const. Co. (1926) 269 U.S. 

385, 391.) Although even noncriminal legislation can be void for vagueness (see 

A.B. Small Co. v. American Sugar Refining Co. (1925) 267 U.S. 233, 239), 

“economic regulation is subject to a less strict vagueness test because its subject 

matter is often more narrow . . . and businesses, which face economic demands to 

plan behavior carefully, can be expected to consult relevant legislation in advance 

of action. . . . ” (Hoffman Estates v. Flipside, Hoffman Estates (1982) 455 U.S. 

 

6 The current version of ICRAA continues to exclude credit reports that are 

“limited to specific information relating to a consumer’s credit record or manner 

of obtaining credit obtained directly from a creditor.” (§ 1786.2, subd. (c).)
8

489, 498; cf. Ford Dealers Assn. v. Dep’t of Motor Vehicles (1982) 32 Cal.3d 347, 

366.) 

The threshold question here is one of statutory interpretation. If we 

conclude that ICRAA and CCRAA are sufficiently clear to indicate that both 

apply to Connor’s background report, neither statute is vague. (Cf. United States

v. Batchelder (1979) 442 U.S. 114, 123 [That “particular conduct may violate both 

Titles does not detract from the notice afforded by each”].) 

In cases involving statutory interpretation, our “ ‘ “fundamental task . . . is 

to determine the Legislature’s intent so as to effectuate the law’s purpose.” ’ 

[Citation.] ‘ “If the statute’s text evinces an unmistakable plain meaning, we need 

go no further.” ’ [Citation.]” (Pacific Palisades Bowl Mobile Estates, LLC v. City 

of Los Angeles (2012) 55 Cal.4th 783, 803.) “We construe statutory language in 

the context of the statutory framework, seeking to discern the statute’s underlying 

purpose and to harmonize its different components.” (Ardon v. City of Los 

Angeles (2016) 62 Cal.4th 1176, 1183.) Keeping these statutory interpretation 

principles in mind, we turn to the parties’ arguments. 

First’s principal contention is that CCRAA and ICRAA were initially 

intended to be exclusive of each other and that the 1998 amendment was not 

intended to abolish that distinction. First’s vagueness argument—that the overlap 

created by the ICRAA amendment renders the statute unconstitutionally vague 

whenever CCRAA also might apply—follows the holding of Ortiz v. Lyon 

Management Group, Inc. (2007) 157 Cal.App.4th 604 (Ortiz). By contrast, 

Connor asserts that the two statutes were never exclusive, and the 1998 

amendment did not change that fact. 

In Ortiz, an apartment rental applicant, who was approved after a rental 

manager’s unlawful detainer search came up clear, sued the management company 

for violating ICRAA because it failed to provide her with a check box to request a 
9

copy of the background report, and because it had not provided her written notice. 

(Ortiz, supra, 157 Cal.App.4th at p. 611.) The trial court noted that the report 

showed no unlawful detainer actions, but it commented that if the report had 

shown them, that would not have proved the plaintiff’s bad character. The court 

held that the plaintiff’s claim could not stand because it required extending 

ICRAA into CCRAA’s domain, and thus would render ICRAA unconstitutionally 

vague and inconsistent with federal law. It dismissed the plaintiff’s claim. (Id. at 

p. 612.) 

The Court of Appeal in Ortiz viewed the issue as a “categorization 

challenge” and agreed with the trial court, reasoning that the Legislature intended 

consumer reports to fall under either ICRAA or CCRAA, but not both. (Ortiz, 

supra, 157 Cal.App.4th at p. 612.) The court held that the categorization 

challenge “arises not because unlawful detainer information is somehow 

paradoxical, but because the statutory scheme fails to set forth truly distinct 

categories. It presents a false dichotomy between creditworthiness and character.” 

(Id. at pp. 612-613.) The court reasoned that because unlawful detainer 

information could relate to both a consumer’s character and creditworthiness, and 

because ICRAA did not give adequate notice whether ICRAA or CCRAA governs 

for tenant screenings, ICRAA was unconstitutionally vague in this situation. (Id. 

at pp. 618–619.) First asks us to extend Ortiz to background checks in the 

employment context. 

Ortiz’s holding was based on a categorical view of the two statutes as the 

court interpreted their legislative history—especially focusing on the fact that the 

Legislature modeled both statutes after FCRA. (15 U.S.C. § 1681 et seq.) Ortiz 

relied on the history of both acts as originally enacted, when ICRAA governed 

consumer reports that included character information obtained through personal 

interviews only. The court concluded that the Legislature created two separate 
10

statutory schemes intended to cover either creditworthiness or character 

information, but not both. (Ortiz, supra, 154 Cal.App.4th at pp. 614-616; see 

Trujillo v. First American Registry, Inc. (2007) 157 Cal.App.4th 628, 640

[companion case to Ortiz finding ICRAA unconstitutionally vague in the case of 

unlawful detainer action reports generated for tenant screening because it is 

“hopelessly uncertain” which statute should apply].) 

As the Court of Appeal observed here, “[w]hen the Legislature amended 

ICRAA in 1998 to remove the limitation on [its scope] so it would govern all 

consumer reports that include character information, no matter how that 

information is obtained, it did not amend CCRAA to exclude from its scope 

reports that include character information obtained from sources other than 

personal interviews.” Even after the amendment, “consumer reports that include 

character information obtained from a source other than personal interviews 

continue to be governed by CCRAA, as long as the reports contain information 

‘bearing on a consumer’s credit worthiness, credit standing, or credit capacity.’ 

(§ 1785.3, subd. (c).) But they also are governed by ICRAA under its clear and 

unambiguous language.” The Court of Appeal found Ortiz inconsistent with our 

own precedent governing the interpretation of overlapping statutes. 

In interpreting ICRAA and CCRAA, we agree with the Court of Appeal 

and find that potential employers can comply with both statutes without 

undermining the purpose of either. If an employer seeks a consumer’s credit 

records exclusively, then the employer need only comply with CCRAA. An 

employer seeking other information that is obtained by any means must comply 

with ICRAA. In the event that any other information revealed in an ICRAA 

background check contains a subject’s credit information and the two statutes thus 

overlap, a regulated party is expected to know and follow the requirements of both 

statutes, even if that requires greater formality in obtaining a consumer’s credit 
11

records (e.g., seeking a subject’s written authorization to conduct a credit check if 

it appears possible that the information ultimately received may be covered by 

ICRAA). (See e.g., Powell v. U.S. Cartridge Co. (1950) 339 U.S. 497, 519.) 

In a related argument, First asserts that because ICRAA and CCRAA cover 

the same subject matter, it is unclear which statute applies in the context of 

employment background checks. However, Connor’s example of a report that 

would fall within the scope of both ICRAA and CCRAA is simply one that 

contains information bearing on both a consumer’s creditworthiness and on her 

character. It seems to us that such a duality does not make legal compliance 

particularly difficult, much less impossible.

Indeed, the terms of the 2010 notice that First sent to Connor contemplated 

that the background check was an investigative consumer report within the scope 

of ICRAA. Part 1 of the Notice is titled, “INVESTIGATIVE CONSUMER 

REPORT DISCLOSURE AND RELEASE.” The report’s first sentence reads: 

“In connection with your employment or application for employment (including 

contract for services) an investigative consumer report and consumer reports, 

which may contain public record information, may be requested from USIS.” The 

notice specifically states that the reports may include “information relating to your 

character, general reputation, educational background, or any other information 

about you which may reflect upon your potential for employment gathered from 

any individual, organization, entity, agency, or other source which may have 

knowledge concerning any such items of information.” By its terms, the 2010 

notice conveys that First understood that the background check would include 

information about Connor’s character, thus placing it within the scope of ICRAA. 

Additionally, the check box portion of the notice cites to ICRAA, Civil Code 
12

section 1786.22, and provides details about the consumer’s statutory rights, again 

indicating that First had notice that it must comply with ICRAA. 

First alternatively contends that if the Legislature intended ICRAA to apply 

to employment screening reports that previously were exclusively subject to 

CCRAA, it would have amended CCRAA to conform to this understanding. The 

pertinent portion of CCRAA, however, speaks in limiting language, rather than 

language of authorization. (See Civ. Code, § 1785.11, subd. (a)(3)(B) [“A 

consumer credit reporting agency shall furnish a consumer credit report only under 

the following circumstances: [¶] . . . [¶] (3) To a person whom it has reason to 

believe: [¶] . . . [¶] (B) Intends to use the information for employment purposes” 

(italics added)].) Accordingly, there was no need for the Legislature to amend 

CCRAA in response to the changes it made to ICRAA.

Only ICRAA governs reports obtained from personal interviews that bear 

solely on an individual’s character. (See § 1785.3, subd. (c)(5).) Meanwhile, only 

CCRAA, which limits its applicability to information gathered and used for 

employment purposes, governs credit information obtained directly from creditors 

for developing a consumer’s credit record. (§ 1785.11, subd. (a)(3)(B) [limiting 

access to consumer credit reports to persons the consumer credit reporting agency 

has reason to believe “intends to use the information for employment purposes”].) 

Any partial overlap between the statutes does not render one superfluous or 

unconstitutionally vague. They can coexist because both acts are sufficiently clear

(cf. Batchelder, supra, 442 U.S. at p. 123), and each act regulates information that 

the other does not (see J.E.M. Ag Supply, Inc. v. Pioneer Hi-Bred International, 

Inc. (2001) 534 U.S. 124, 144 [when considering statutory protections for plant 

varieties, court may “give effect to two statutes that overlap, so long as each 

reaches some distinct cases”]).
13

To the extent that Ortiz v. Lyon Management Group, Inc., supra, 157 

Cal.App.4th 604, and its companion case Trujillo v. First American Registry Inc.,

supra, 157 Cal.App.4th 628 hold otherwise, we disapprove them. 

CONCLUSION

The background check that First conducted here is an investigative 

consumer report under ICRAA because it reported on Connor’s “character, 

general reputation, personal characteristics, or mode of living.” (§ 1786.2, subd. 

(c).) That CCRAA also applies here does not exempt First from the requirement 

that it obtain Connor’s written authorization under ICRAA before conducting or 

procuring a background investigation. (§1786.16, subd. (a)(2)(C).)

For the foregoing reasons, we affirm the Court of Appeal judgment and remand 

the matter for further proceedings consistent with this opinion.

CHIN, J.

WE CONCUR:

CANTIL-SAKAUYE, C.J.

CORRIGAN, J.

LIU, J.

CUÉLLAR, J.

KRUGER, J.

ROBIE, J.*

——————————————————

* Associate Justice of the Court of Appeal, Third Appellate District, assigned 

by the Chief Justice pursuant to article VI, section 6 of the California Constitution.
See next page for addresses and telephone numbers for counsel who argued in Supreme Court.

Name of Opinion Connor v. First Student, Inc.

__________________________________________________________________________________

Unpublished Opinion

Original Appeal

Original Proceeding

Review Granted XXX 239 Cal.App.4th 526

Rehearing Granted

__________________________________________________________________________________

Opinion No. S229428

Date Filed: August 20, 2018

__________________________________________________________________________________

Court: Superior

County: Los Angeles

Judge: John Shepard Wiley, Jr.

__________________________________________________________________________________

Counsel:

Sundeen Salinas & Pyle, Hunter Pyle Law, Hunter Pyle, Tanya Tambling, Rachel Evans, Chad Saunders; 

Lewis, Feinberg, Renaker, Lee & Jackson, Lewis, Feinberg, Lee & Jackson, Feinberg, Jackson, Worthman 

& Wasow, Todd F. Jackson and Catha Worthman for Plaintiff and Appellant.

Kamala D. Harris, Attorney General, Nicklas A. Akers, Assistant Attorney General, Michele Van 

Gelderen and Alicia K. Hancock, Deputy Attorneys General, for Attorney General as Amicus Curiae on 

behalf of Plaintiff and Appellant.

Law Offices of Craig Davis and Craig Davis for A New Way of Life Reentry Project, Bay Area Legal Aid, 

Bet Tzedek Legal Services, Center for Employment Opportunities, Collateral Consequences Resource 

Center, Community Service Society of New York, Drug Policy Alliance, East Bay Community Law 

Center, Ella Baker Center for Human Rights, Equal Rights Advocates, Lawyers’ Committee for Civil 

Rights of the San Francisco Bay Area, Legal Action Center, Legal Aid Foundation of Los Angeles, Legal 

Aid of Marin, Legal Services for Prisoners with Children, Legal Services of Northern California, National 

Consumer Law Center, Neighborhood Legal Services of Los Angeles County, North Carolina Justice 

Center, Public Counsel, Public Interest Law Project, Public Law Center, Root & Rebound, Rubicon 

Programs and Western Center on Law and Poverty as Amici Curiae on behalf of Plaintiff and Appellant.

Seth E. Mermin, Thomas Bennigson and Jonathan S.M. Francis for California Reinvestment Coalition, 

Consumer Action, Consumers for Auto Reliability and Safety, Housing and Economic Rights Advocates, 

National Association of Consumer Advocates, National Employment Law Project, National Housing Law 

Project and Public Good Law Center as Amici Curiae on behalf of Plaintiff and Appellant.

Littler Mendelson, Benjamin A. Emmert and Ronald A. Peters for Defendants and Respondents.

Covington & Burling, Andrew M. Smith and Simon J. Frankel for the Consumer Data Industry Association 

as Amicus Curiae on behalf of Defendants and Respondents.
Counsel who argued in Supreme Court (not intended for publication with opinion):

Hunter Pyle

Hunter Pyle Law

428 13th Street, 11th Floor

Oakland, CA 94612

(510) 663-9240

Seth E. Mermin

Public Good Law Center

3130 Shattuck Avenue

Berkeley, CA 95705

(510) 393-8254

Ronald A. Peters

Littler Mendelson

50 West San Fernando Street, 14th Floor

San Jose, CA 95113-2431

(408) 998-4150