Case 1:13-cv-01247 Document 1 Filed 08/15/13 Page 1 of 16

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

CERTEGY CHECK SERVICES, INC., a 

Delaware corporation, 

Defendant. 

Civil Action No. 

COMPLAINT FOR CIVIL PENAL TIES, PERMANENT 

INJUNCTION, AND OTHER EqiDTABLE RELIEF 

Plaintiff, the United States of America, acting upon notification and authorization of the 

Attomey General by the Federal Trade Commission ("FTC"), for its Complaint alleges: 

1. Plaintiffbrings this action under sections 5(a), 5(m)(l)(A), 13(b), 16(a)(l), and 19 

of the Federal Trade Commission Act ("FTC Acf'), 15 U.S.C. §§ 45(a), 45(m)(l)(A), 53(b), 

56(a)(l), and 57b; and section 62I(a) of the Fair Credit Reporting Act (''FCRA"), 15 U.S.C. 

§ 1681 s( a), to obtain monetary civil penalties and injunctive or other relief for violations of the 

FTC Act, 15 U.S.C. §§ 45(a) and 57b; the FCRA, 15 U.S.C. §§ 1681-1681x, as amended by 

sections 211 and 312 ofthe Fair and Accurate Creait Transactions Act of2003, Pub. L. No. 108-

159, 117 Stat. 1952 (2003) ("FACT Act") and by sections 1061 and 1088 of the Dodd-Frank 

Wall Street R~form and Consumer Protection Act, Pub. L. 111-203, 124 Stat. 1376 (2010) 

(codified in scattered sections of 12 U.S.C.) ("Dodd-Frank Act"); the Free Annual File 

Disclosures Rule, 16 C.F.~.J 610, issued pursuant to section 612(a)(l)(C)(i) of the FCRA, 15 

!$' U.S.C. § 1681j(a)(l)(C)(i), and recodified as Duties of Consumer Reporting Agencies Regarding 

Disclosures to Consumers, 12 C.F .R. § 1022, subpart N; and the Duties of Furnishers of 

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Case 1:13-cv-01247 Document 1 Filed 08/15/13 Page 2 of 16

Information to Consumer Reporting Agencies Ru1e, 16 C.F.R. § 660, issued pursuant to section 

623(e)(l) of the FCRA, 15 U.S.C. § 1681s-2(e)(1), and recodified as Duties ofFurnishers of 

Information, 12 C.F.R. § 1022, subpart E. 

JURISDICTION AND VENUE 

': 2. __ This Court has subject matter jurisdiction over this matter under 28 U.S. C. 

§§ 1331, 1337(a), 1345, and 1355, and under 15 U.S.C. §§ 45(a), 45(m)(A), 53(b), 56(a), 1681s, 

and 16921. 

3. Venue is proper in this district under 28 U.S.C. §§ 1391(b)-(c), 1395(a), and 15 

u.s.c. § 53(b). 

PLAINTIFF 

4. This action is brought by the United States of America on behalf of the FTC. The 

FTC is an independent agency ofthe United States government given statutory authority and 

responsibility by, inter alia, the FTC Act, as amended, 15 U.S.C. §§ 41-58, and the FCRA, as 

amended, 15 U.S.C. §§ 1681-168lx. The FTC is charged with enforcing section 5(a) of the FTC 

Act, 15 U.S.C. § 45(a), which prohibits unfair and deceptive acts or practices. in or affecting 

commerce, and the FCRA, which imposes duties upon consumer reporting agencies. Pursuant to 

the FCRA, the FTC promulgated and enforces the Free Annual File Disclosures Rule, 16 C.F .R. 

§ 610, effective December 1, 2004, recodified as promulgated by the CFPB as Duties of 

Consumer Reporting Agencies Regarding Disclosures to Consumers, 12 c:F.R. § 1022, subpart 

N, effective July 21, 2011; and the Duties ofFurnishers oflnformation to Consumer Reporting 

Agencies Rule, 16 C.P.R. § 660, effective August 1, 2005, recodified as promulgated by the 

CFPB as Duties of Furnishers ofinfonnation, 12 C.F.R. § 1022, subpart E, effective July 21, 

p 2011. 

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DEFENDANT 

5. Defendant Certegy Check Services, Inc. ("Certegy") is a Delaware corporation 

with its principal place of business in St. Petersburg, Florida. Certegy transacts or has transacted 

business in this district. 

COMMERCE 

6. At all times material to this Complaint, Certegy has maintained a substantial 

course of trade in or affecting commerce, as "commerce" is defined in section 4 of the FTC Act,. 

15 u.s.c. § 44. 

FAIR CREDIT REPORTING ACT 

7. The FCRA was enacted in 1970, became effective on April25, 1971, and has 

been in force since that date. The FACT Act amended the FCRA in December 2003, and the 

Dodd-Frank Act amended the FCRA in July 2010. 

8. Section 621 of the FCRA, 15 U.S.C. § 168ls, authorizes the FTC to use all of its 

functions and powers under the FTC Act to enforce compliance with the FCRA by all persons 

subject thereto except to the extent that enforcement specifically is committed to some other 

governmental agency, irrespective of whether the perso9- is engaged in commerce or meets any 

other jurisdictional tests set forth by the FTC Act. 

9. Section 612(a)(l)(C)(i) of the FCRA, IS·U.S;C. § 1681j(a)(l)(C)(i) required the 

FTC to prescribe regulations to require the establishment of a streamlined process for consumers 

to request consumer reports; and section 623(e)(l) of the FCRA, 15 U.S.C. § 168ls-2(e)(1) 

required the FTC to establish and maintain guidelines for furnishers regarding the accuracy and 

integrity of information, ~~to prescribe regulations requiring furnishers to establish reasonable 

"""" policies and procedures to implement those guidelines. The FTC published those regulations, 

respectively, at 16 C.F.R. § 610 and 16 C.F.R. § 660. In July 2011, the Dodd-=Frank Act 

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transferred this rulemaking authority to the Consumer Financial Protection Bureau ("CFPB''), 

and the CFPB republished those regulations at 12 C.F .R. § 1022, respectively at subparts N and 

E. The FTC enforces these CFPB regulations with respect to entities over which the FTC retains 

jurisdiction under the FCRA 

· ...... 10.-- Certegy is now and has been a consumer reporting agency ("CRA"), as defined in 

Section 603(f) ofthe FCRA, 15 U.S.C. § 1681a(f): 

any person which, for monetary fees, dues, or on a cooperative nonprofit basis, 

regularly engages in whole or in part in the practice of assembling or evaluating 

consumer credit information or other information on consumers for the purpose of 

furnishing consumer reports to third parties, and which uses any means or facility 

of interstate commerce for the purpose of preparing or furnishing consumer 

reports_ 

Certegy regularly sells in interstate commerce consumer information it assembles for the purpose 

of furnishing consumer reports to its clients. 

11. The FCRA imposes several obligations upon CRAs, including obHgations to: 

a) follow reasonable procedures to assure the maximum possible 

accuracy of consumer report information; and 

b} take certain steps when a co11sumer disputes information m h1s or her 

file, including: completing a reasonable reinvestigation within a set 

time period; providing prompt notice of disputes to furnishers; 

promptly deleting inaccurate, incomplete, or unverifiable information; 

promp_tly notifying the furnisher that information has been modified or 

deleted; maintaining reasonable procedures designed to prevent the 

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reappearance of deleted information; and promptly providing notice to 

the consumer of the results of1ts investigation. 

Sections 607(b), 611 of the FCRA, 15 U.S.C. §§ 1681e(b), 1681i. 

12. Certegy also is now and has been a "nationwide specialty consumer reporting 

a:gency;'' which is defined in section 603(x) of the FCRA, 15 U.S.C. § 1681a(x), as "a consumer 

reporting agency that compiles and maintains files on consumers on a nationwide basis relating 

to: (1) medical records or payments; (2) residential or tenant history; (3) check writing his~ory; 

( 4) employment history; or ( 5) insurance claims." Certegy compiles and maintains files relating 

to, inter alia, the check-writing history of individuals who reside in most, if not all, of the fifty 

United States and the District of Columbia. 

13. The FCRA imposes several obligations upon nationwide specialty CRAs, 

including an obligation to provide to each consumer a free annual disclosure of information in 

the consumer's file ("annual file disclosure''). The FCRA further requires that nationwide 

' 

specialty CRAs have a streamlined process for accepting and processing consumer requests for . 

annual file disclosures that is designed, funded, implemented, maintained, and operated in 

manner that collects only as much personal information as is necessary to properly identify the 

consumer. 16 C.F.R. § 610.3,recodified at 12 C.F.R. § 1022.137. 

14. Certegy also is now and has been a·''fu.nlisher of information" to CRAs, as 

described in section 623(a)(2)(A) of the FCRA, 15 U.S.C. § 1681s-2(a)(2)(A), because it 

''regularly and in the ordinary course ofbusiness furnishes information to one or more CRAs" 

about its "transactions or experiences" with consumers. Certegy regularly reports information to 

Equifax, which is another CRA, as defined in section 603(f) of the FCRA, 15 U.S.C. § 1681a(f). 

I 

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15. The FCRA imposes several obligations up.on furnishers of information to CRAs,' 

including obligations to establish and implement reasonable written policies and procedures 

regarding the accuracy and integrity of the information relating to consumers that it furnishes to 

a CRA. 16 C.F.R. § 660.3, recodified at 12 C.F.R. § 1022.42. 

DEFENDANT'S BUSINESS PRACTICES 

16. Certegy provides check authorization recommendations to merchants throughout 

. the United States as to whether to accept consumers' checks; These recommendations take into 

account the consumers' identification provided at the point of sale; any unpaid debts in the form 

of previous returned checks; and a variety pf risk factors bearing on the likelihood that a check 

will be returned unpaid by the consumer's financial institution. 

17. The check authorization recommendations that Certegy provides are designed to 

assist merchants in deciding whether to accept consumers' checks and are, therefore, consumer 

reports as defined in section 603(d) ofthe FCRA, 15 U,S.C. § 1681a(d): 

any \vritten, oral, or other communication of any information by a consumer 

reporting agency bearing on a consumer's credit worthiness, credit standing~ 

credit capacity, character, general reputation, personal characteristics, or mode of 

living which is used or expected to be used or collected in whole or in part for the 

purpose of serving as a factor in establishing the consumer's eligibility for (A) 

credit or insurance to be used primarily for personal, family, or household 

purposes; (B) employment purposes; or (C) any other purpose authorized under 

section 604. 

Certegy' s reports are commlilf~~~ted to third parties; bear on, inter alia, consumers' credit 

<JF" worthiness, character, general reputation, or personal characteristics; and are used or expected to 

be used in connection with business transactions that a consumer has initiated. 

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Accuracv of Consumer Report Information 

18. Section 607(b) of the FCRA, 15 U.S.C. § 1681e(b), requires CRAs to follow 

reasonable procedures to "assure the maximum possible accuracy of the information concerning 

the individual about whom the report relates." 

. --~ . -I-9. In numerous instances, Certegy failed to follow reasonable procedures to assure 

maximum possible accuracy of consumers' report information. Among other things, Certegy 

failed to adequately track the handling and resolution of consumer disputes, resulting in its · 

failure to promptly delete inaccurate or unverifiable information. This failure led to the retention 

and reporting of inaccurate consumer report information regarding consumers who may have 

been denied the ability to pay by check at the thousands of merchants who use Certegy's checkauthorization services. 

Reinvestigations ofDisputed Information 

20. Section 611 of the FCRA, 15 U.S.C. § 1681i, requires CRAs to, inter alia, 

conduct reasonable remvestigations to detennine whether disputed information is inaccurate 

within thirty days or, if the period oftime is extended, within forty-five days; to provide prompt 

notice of disputes to furnishers upon receipt of notice of the dispute from consumer; where 

appropriate, to notify consumers that a dispute is frivolous or irrelevant; to promptly delete 

inaccurate, i:p.complete, or unverifiable information; ·to promptly notify the furnisher that 

information has been modified or deleted; to maintain reasonable procedures designed to prevent 

the reappearance of deleted information in consumers' files; and to promptly provide notice to 

consumers of the results of its investigations. 

21. In many ins}~ces, when consumers notify Certegy that they dispute the accuracy 

'&""' or completeness of information in their file, Certegy attempts to shift the burden of conducting a 

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reinvestigation to consumers rather than fulfilling its legal obligation to reinvestigate disputed 

information. For example: 

a. If a consumer disputes that he has a returned check from a particular 

merchant, Certegy requires the consumer to contact the merchant himself to 

resolve the dispute; 

b. When the decline is the result of an ''invalid" ID, Certegy requires that the 

consumer obtain and send driving records to Certegy to ''prevent future 

declines"; and 

c. When the consumer disputes that the consumer's bank refused to honor a 

check, rather than accepting a bank state:rnent as proof of the bank's payment, 

Certegy :equires that the consumer obtain a letter from the bank, on bank 

letterhead, signed by a bank employee before it will resolve the dispute in the 

consumer's favor. 

In many instances, if consumers do not comply with Certegy' s requirements, Certegy does not 

independently pursue the reinvestigation and retains the disputed information in the consumer's 

file. These practices often result in reinvestigations not being completed within thirty to fortyfive days and make it more difficult for consumers to have inaccurate or unverifiable information 

removed from their files. 

22. In many instances, when Certegy reinvestigates disputed items in consumers' 

files, it: 

a) Fails to complete reinvestigations within thirty days or, ifCertegy 

received information from the consumer during the thirty-day period 

that is relevant to the reinvestigation, within fortj-:five days; 

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b) Fails to provide, before the expiration of the five-business-day period 

beginning on the date on which Certegy receives notice of a dispute 

from any consumer, notification of the dispute to any furnisher of 

disputed information, at the address and in the manner established with 

the person, including an relevant information regarding the dispute 

that Certegy has received from the consumer; 

c) Fails to notify the consumer, within five business days, by mail or 

other means authorized by the consumer for that purpose, when it has 

terminated a reinvestigation of information disputed by a consumer, 

because it reasonably determined that the consumer's dispute was 

frivolous or irrelevant; 

d) After conducting a reinvestigation of information disputed by a 

consumer and finding that an item of information is inaccurate, 

incomplete, or cannot be verified, fails to: 

1. promptly delete or modify an item of information from the 

consumer's file, as appropriate; and/or 

n. promptly notify the furnisher of that information that the 

information has been modified or deleted from the consumer's 

file; 

e) Fails to maintain reasonable procedures designed to prevent the 

reappearance in a consumer's file, and in consumer reports on the 

,con.sumer, of information that is deleted pursuant to a reinvestigation. 

As a result, if a merchant subsequently re-reports to Certegy 

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information that Certegy previously deleted, Certegy will include this 

information in its consumer file because it has no system or procedure 

to verify whether the information was previously determined to be 

inaccurate or unverifiable; and 

f) Fails to provide written notice to a consumer of the results of a 

reinvestigation not later than five business days after the completion of 

the reinvestigation. 

Consumer File Disclosures and Streamlined Process 

23. Section 612(a)(2) of the FCRA, 15 U.S.C. § 1681j(a)(2), requires CRAs to 

"provide a consumer report under paragraph (I) not later than 15 days after the date on which the 

request is received," and paragraph (1), in turn, requires nationwide specialty CRAs to comply 

with the regulations prescribed pursuant to section 612(a)(l)(C) of the FCRA, 15 U.S.C. 

§ 1681j(a)(I)(C). 

24. The Free Annual File Disclosures Rule~ 16 C.F.R. § 610, recodified as Duties of. 

Consumer Reporting Agencies Regarding Disclosures to Consumers, 12 C.F .R. § 1022, subpart 

N, requires, inter alia, that nationwide specialty CRAs "have a streamlined process for accepting 

and processing consumer requests for annual file disclosures" that is "designed, funded, 

implemented, maintained, and operated in manner tha:t: .. collects only as much pers-onal 

information as is necessary to properly identify the consumer under the FCRA." 16 C.F .R. 

§ 610.3(a)(2), recodified at 12 C.F.R. § 1022.137(a)(2). 

25. In many instances, consumers have difficulty obtaining their annual file 

disclosures from Certegy because Certegy, among other things requires consumers to submit 

,~c- more infom1ation than is reasonably necessary to properly identify the consumers before Certegy 

provides their annual tlle disclosures. As a result, in numerous instances, Certegy made it more 

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difficult for consumers to obtain their annual file disclosures, resulting in delays or the 

nonfulfillment of consumers' requests. In many instances, Certegy did not provide consumers 

with their annual file disclosures within fifteen days of receiving their requests. 

Written Policies (Furnisher) 

26. The Duties of Furnishers of Information to Consumer Reporting Agencies Rule, 

16 C.F.R. § 660, recodified as Duties ofFumishers of Information, 12 C.F.R. § 1022, subpart E, 

states that furnishers must establish and implement reasonable written policies and procedures 

regarding the .accuracy anfi integrity of the information relating to consumers that it furnishes to 

CRAs, must consider the guidelines in appendix E of that rule, and must review its policies and · 

procedures periodically. 16 C.F.R. § 660.3, recodified at 12 C.P.R.§ 1022.42. 

27. Certegy has failed to establish and implement reasonable written policies and 

procedures regarding the accuracy and integrity of the information relating to consumers that it 

furnishes to CR,As, failed to consider the guidelines in appendix E of that rule, and failed to 

review its policies and procedures periodically. 

28. Certegy' s failures coul<p ead to either .the reporting of inaccurate information to 

CRAs or the retention of inaccurate information in CRAs' files, and in some instanc.es to both. 

VIOLATIONS OF THE FAIR CREDIT REPORTING ACT 

COUNT!··· 

Accuracy of Consumer Report Information 

29. As described above in paragraph 19, Certegy failed to use reasonable procedUres 

to assure maximum possible accuracy of consumer report information. 

30. By and through the acts and.practices described in paragraphs 19 and 29, Certegy 

has violated section 607(b) of the FCRA, 15 U.S.C. § 1681e(b). 

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31. Pursuant to section 62l(a)(l) ofthe FCRA, 15 U.S.C. § 168Is(a)(l), the acts and 

practices alleged in paragraph 30 also constitute unfair or deceptive acts or practices in violation 

of section 5(a) of the FTC Act, 15 U.S.C. § 45(a)._ 

COUNT II 

Reinvestigations ofDisputed Information 

32. As described above in paragraphs 2 I and 22, on numerous occasions, Certegy has 

failed to follow the steps required by section 611, including failing to complete the 

reinvestigation within thirty days or, if the period of time is extended, within forty-five days; 

failing to provide prompt notice of disputes to furnishers upon receipt of notice of the dispute 

from consumer; failing to, where appropriate, provide notice of a determination that a dispute is 

frivolous or irrelevant; failing to promptly delete inaccurate, incomplete, or unverifiable 

information; failing to promptly notify the furnisher that information has been modified or 

deleted; failing to maintain reasonable procedures designed to prevent the reappearance of 

deleted information in a consumer's file; and failing to promptly provide notice to the consumer 

of the results of its investigation. 

33. By and through the acts and practices described in paragraphs 21, 22, and 32, 

Certegyhas violated sections 611(a)(l), (2), (3), (5), and (6) ofthe FCRA, 15 U.S.C. 

§§ 168Ii(a)(l), (2), (3), (5), and (6). 

34. Pursuant to section 62l(a)(l) ofthe FCRA, 15 U.S.C. § 1681s(a)(I), the acts and 

practices alleged in paragraph 33 also constitute unfair or deceptive acts or practices LTl violation 

of section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

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COUNT III 

Consumer File Disclosures and Streamlined Process 

35. As described above in paragraph 25, Certegy has not established the streamlined 

process required by 16 C.P.R.§ 610.3, recodified at 12 C.P.R.§ 1022.137, for consumers to 

. request free annual file disclosures. Among other things, Certegy does not have a process that is 

designed, implemented, or maintained to comply with the rule; it routinely collects more 

personal information than is reasonably necessary to identify the consumer requesting his or her 

report; and it often fails to provide consumer reports within fifteen days of receiving consumers' 

requests for their free reports. 

36. By and through the acts and practices descnbed in paragraphs 25 and 35, Certegy 

has violated section 612(a)(2) ofthe FCRA, 15 U.S.C. § 168lj(a)(2), and 16 C.P.R.§ 610.3, 

recodified at 12 C.P.R.§ 1022.1~7. 

37. ·Pursuant to section 621(a)(l) of the PCRA, 15 U.S.C. § 1681s(a)(l), the acts and 

practices alleged in paragraph 36 also constitute unfair or deceptive acts or practices in violation 

of section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

COUNT IV 

Written Policies (Furnishers) 

38. As described in paragraph 27; Certegy has· failed to establi~h and implement 

reasonable written policies and procedures regarding the accuracy and integrity of the 

information relating to consumers that it furnish to CRAs, failed to consider the guidelines in 

appendix E of that rule, and failed to review its policies and procedures periodically as required 

by 16 C.P.R.§ 660.3, recodified at 12 C.P.R.§ 1022.42. 

3 9. By and through the acts and practices described in paragraphs 27 fu1d 3 8, Certeg-y 

has violated 16 C.P.R.§ 660.3,recodified at 12 C.P.R.§ 1022.42. 

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40. Pursuant to section 621(a)(l) of the FCRA, 15 U.S.C. § 168Is(a)(l), the acts and 

practices alleged in paragraph 39 also constitute unfair or deceptive acts or practices in violation 

of section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

INJUNCTION FOR VIOLATIONS OF THE FTC ACT AND FCRA 

41~ Under section 621(a) ofthe FCRA, 15 U.S.C. § 1681s(a), and section 13(b) of the 

FTC Act, 15 U.S.C. § 53(b), this Court is authorized to issue a permanent injunction to ensure 

that Certegy will not continue to violate the FTC Act, and the FCRA. 

EQIDT ABLE RELIEF FOR VIOLATIONS OF THE FTC ACT AND FCRA 

42. Under section 621(a) of the FCRA, 15 U.S.C. § 1681s(a) and section 13(b) of the 

FTC Act, 15 U.S.C. § 53(b), this Court is authorized to issue all equitable and ancillary relief as 

it may deem. appropriate in the enforcement of the FTC Act and the FCRA, including the ability 

to order rescission or reformation of contracts, restitUtion, the refund of monies paid, and 

disgorgement to deprive a wrongdoer of ill-gotten gain. 

CIVIL PENALTIES FOR VIOLATIONS OF THE FCRA 

43. Section 621(a)(2)(A) of the FCRA, 15 U.S.C. § 1681s(a)(2)(A), authorizes the 

· Court to award monetary civil penalties in the event of a knowing violation, which constitutes a 

pattern or practice of violations. Certegy's violations of sections 607, 611, and 612, all as 

alleged in this Complaint, were knowing and constituted a pattern or practice of violations. As 

specified by the Federal Civil Penalty Inflation Adjustment Act of 1990; 28 U.S.C. § 2861, as 

amended, the Court i_s authorized to award a penalty of not more than $2,500 per violation for 

violations occurring before February 10, 2009, and $3,500 per violation for viol~tions occurring 

on or after that date. 

44. Each instance in which Certegy has failed to comply with the FCRA in one or 

more of the ways described above constitutes a separate violation of the FCRA for the purpose of 

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assessing monetary civil penalties undef'Section 621 of the FCRA. Plaintiff seeks monetary civil 

penalties for every separate violation of the FCRA. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiffreques.ts that this Court, pursua.pt to 15 U.S.C. §§. 45(a), 

.;,45(m)(l-)(A), 53(b ), 1681 s; and 16921, and pursuant to the Court's own equitable powers: 

(1) Enter judgment against Certegy and in favor ofPlaintifffor each law violation 

alleged in this Complaint; 

(2) Enter a. permanent injunction against Certegy to prevent further violations of the 

FTC Act and the FCRA, as a!leged herein; ' . 

(3) Award Plaintiff monetary civil penalties from Certegy for each violation of the 

FCRA as alleged in this Complaint; 

(4) Order Certegyto pay the costs ofthis action; and 

(5) Award Plaintiff such additional relief as the Court may deem just and proper. 

;ated A~wJ /S , 2013 
Case 1:13-cv-01247 Document 1 Filed 08/15/13 Page 16 of 16

FOR THE UNITED STATES OF 

AMERICA: 

STUART F. DELERY 

Assistant Attorney General 

Civil Division 

United States Department of Justice 

MAAME EWUSI-MENSAH FRIMPONG 

Deputy Assistant Attorney General 

Civil Division 

MICHAEL S. BLUME 

Director 

Consumer 

~ 

Protection Branch 

ANN ENTWISTLE 

Trial Attorney 

Office of Consumer Protection Litigation 

U.S. Department of Justice 

P.O. Box 386 

Washington, D.C. 20044 

FORTHEFEDERALTRADE 

COMMISSION: 

MANEESHA MITHAL 

Associate Director 

Division of Privacy and Identity Protection 

ROBERT SCHOSHINSKI 

Assistant Director 

Division of Privacy and Identity Protection 

KATHERINE ARMSTRONG 

Attorney 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey A venue, NW 

Mail Stop NJ-8100 

Washington D.C. 20001 

Tel: (202) 326-3250 

KEVIN H. MORIARTY 

Attorney 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey A venue, NW 

Mail Stop NJ-8100 

Washington D.C. 20001 

Tel: (202) 326-2949 

KRISTEN ANDERSON 

Attorney 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Avenue, NW 

Mail Stop NJ-8100 

Washington D.C. 20001 

Tel: (202) 326-3209 

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