Case 2:10-cv-00565 Document 1 Filed 04/20/10 Page 1 of 9

UNITED STATES DISTRICT COURT 

DISTRICT OF NEVADA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

CENTRAL CREDIT, LLC, a limited 

liability company, 

Defendant. 

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Civil Action No. 

COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION, 

AND OTHER EQUITABLE RELIEF 

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

Attorney General by the Federal Trade Commission ("FTC" or "Commission"), for its 

Complaint, alleges that: 

I. Plaintiff brings this action under sections 5(a), 13(b), and l6(a) ofthe Federal 

Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a), 53(b), and 56(a); and the Fair Credit 

Reporting Act ("FCRA"), 15 U.S.C. §§ 1681 - 1681x, to obtain monetary civil penalties and 

injunctive or other relieffor Defendant's violations of the FTC Act and the FCRA. 

UNITED STATES DISTRICT COURT 

DISTRICT OF NEVADA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

CENTRAL CREDIT, LLC, a limited 

liability company, 

Defendant. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Civil Action No. 

COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION, 

AND OTHER EQUITABLE RELIEF 

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

Attorney General by the Federal Trade Commission ("FTC" or "Commission"), for its 

Complaint, alleges that: 

I. Plaintiff brings this action under sections 5(a), 13(b), and l6(a) ofthe Federal 

Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a), 53(b), and 56(a); and the Fair Credit 

Reporting Act ("FCRA"), 15 U.S.C. §§ 1681 - 1681x, to obtain monetary civil penalties and 

injunctive or other relieffor Defendant's violations of the FTC Act and the FCRA. 
Case 2:10-cv-00565 Document 1 Filed 04/20/10 Page 2 of 9

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), 53(b), and 56(a) and 1681s. 

3. Venue in the United States District Court for the District of Nevada is proper 

under 15 U.S.C. § 53(b) and under 28 U.S.c. §§ 1391 (b)-(c) and 1395(a). 

DEFENDANT 

4. Defendant Central Credit, LLC ("Central Credit"), a wholly owned subsidiary of 

Global Cash Access, Inc., is a limited liability company with its principal place of business at 

3525 East Post Road, Suite 120, Las Vegas, Nevada 89120. At all times relevant to this 

complaint, Defendant Central Credit has transacted business in this district. 

THE FAIR CREDIT REPORTING ACT 

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

been in force since that date. The Fair and Accurate Credit Transactions Act amended the FCRA 

in December 2003. 

6. Section 621 of the FCRA, 15 U.S.C. § 1681s, authorizes the Commission 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 person is engaged in commerce or meets 

any other jurisdictional tests set forth by the FTC Act. 

VIOLATIONS OF THE FAIR CREDIT REPORTING ACT 

7. Since at least 1956, Central Credit has sold information about consumers' gaming 

experiences and check-cashing transactions to casinos. These entities use the information to 

Page 2 of 9 

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), 53(b), and 56(a) and 1681s. 

3. Venue in the United States District Court for the District of Nevada is proper 

under 15 U.S.C. § 53(b) and under 28 U.S.c. §§ 1391 (b)-(c) and 1395(a). 

DEFENDANT 

4. Defendant Central Credit, LLC ("Central Credit"), a wholly owned subsidiary of 

Global Cash Access, Inc., is a limited liability company with its principal place of business at 

3525 East Post Road, Suite 120, Las Vegas, Nevada 89120. At all times relevant to this 

complaint, Defendant Central Credit has transacted business in this district. 

THE FAIR CREDIT REPORTING ACT 

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

been in force since that date. The Fair and Accurate Credit Transactions Act amended the FCRA 

in December 2003. 

6. Section 621 of the FCRA, 15 U.S.C. § 1681s, authorizes the Commission 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 person is engaged in commerce or meets 

any other jurisdictional tests set forth by the FTC Act. 

VIOLATIONS OF THE FAIR CREDIT REPORTING ACT 

7. Since at least 1956, Central Credit has sold information about consumers' gaming 

experiences and check-cashing transactions to casinos. These entities use the information to 

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Case 2:10-cv-00565 Document 1 Filed 04/20/10 Page 3 of 9

make eligibility determinations for extending credit or accepting checks, or in connection with 

the review of or collection of a consumer's credit account. 

8. Central Credit maintains information relating to the check-writing history of 

individuals who reside in most if not all of the fifty United States and the District of Columbia. 

Central Credit's databases contain information relating to consumers' credit and check-cashing 

transactions at various casinos. Central Credit sells credit reports to casinos ("Subscribers"), 

which use the reports to make credit decisions or licensing decisions. In addition, Central Credit 

provides a check verification service and a check warranty service to its Subscribers. 

9. The reports Central Credit provides to its Subscribers are designed to improve 

credit decisions, including decisions about the extension of credit. These reports are "consumer 

reports," which are defined in section 603(d) of the FCRA, 15 U.S.c. §1681a(d), as follows: 

any written, 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. 

Central Credit's reports are communicated to third parties, bear on the consumer's credit 

worthiness and/or other attributes listed in section 603(d), and are used as a factor in determining 

the consumer's eligibility for credit, employment, or other purposes specified in section 603(d). 

10. Central Credit is now and has been a "consumer reporting agency," which is 

defined in section 603(t) of the FCRA, 15 U.S.c. § 1681a(t), as follows: 

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 

Page 3 of 9 

make eligibility determinations for extending credit or accepting checks, or in connection with 

the review of or collection of a consumer's credit account. 

8. Central Credit maintains information relating to the check-writing history of 

individuals who reside in most if not all of the fifty United States and the District of Columbia. 

Central Credit's databases contain information relating to consumers' credit and check-cashing 

transactions at various casinos. Central Credit sells credit reports to casinos ("Subscribers"), 

which use the reports to make credit decisions or licensing decisions. In addition, Central Credit 

provides a check verification service and a check warranty service to its Subscribers. 

9. The reports Central Credit provides to its Subscribers are designed to improve 

credit decisions, including decisions about the extension of credit. These reports are "consumer 

reports," which are defined in section 603(d) of the FCRA, 15 U.S.c. §1681a(d), as follows: 

any written, 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. 

Central Credit's reports are communicated to third parties, bear on the consumer's credit 

worthiness and/or other attributes listed in section 603(d), and are used as a factor in determining 

the consumer's eligibility for credit, employment, or other purposes specified in section 603(d). 

10. Central Credit is now and has been a "consumer reporting agency," which is 

defined in section 603(t) of the FCRA, 15 U.S.c. § 1681a(t), as follows: 

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 

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Case 2:10-cv-00565 Document 1 Filed 04/20/10 Page 4 of 9

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. 

Central Credit regularly sells in interstate commerce information on consumers that it assembles 

for the purpose ofJUrnishing consumer reports to its Subscribers. 

11. Central Credit also is now and has been a "nationwide specialty consumer 

reporting agency," which is defined in section 603(w) of the FCRA, 15 U.S.C. § 1681a(w), as 

follows: 

a consumer reporting agency that compiles and maintains files on consumers on a 

nationwide basis relating to (l) medical records or payments; (2) residential or 

tenant history; (3) check writing history; (4) employment history; or (5) insurance 

claims. 

Central Credit compiles and maintains files on consumers on a nationwide basis that 

relate, inter alia, to consumers' check-writing history. As a nationwide specialty consumer 

reporting agency, Central Credit is subject to, among other sections, 609 and 612 ofthe FCRA, 

15 U.S.C. §§ 1681g and 1681j, and the FTC's Streamlined Process Rule, 16 C.F.R. § 610.3. 

COUNT I -- Violations of Section 607(d) of the FCRA 

12. Section 607(d)(l) of the FCRA, IS U.S.C. § 168Ie(d)(I), requires that a consumer 

reporting agency provide, to any person who regularly and in the ordinary course of business 

furnishes information about any consumer to the consumer reporting agency ("furnisher"), a 

"Notice To Furnishers ofInformation: Obligations of Furnishers Under the FCRA" ("Furnisher 

Notice"), the acceptable content of which is set forth in 16 C.F.R. Part 698, Appendix G. Section 

607(d)(2) of the FCRA, IS U.S.C. § 168Ie(d)(2), requires that a consumer reporting agency 

provide, to any person to whom it provides a consumer report ("users"), a "Notice To Users of 

Page 4 of 9 

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. 

Central Credit regularly sells in interstate commerce information on consumers that it assembles 

for the purpose ofJUrnishing consumer reports to its Subscribers. 

11. Central Credit also is now and has been a "nationwide specialty consumer 

reporting agency," which is defined in section 603(w) of the FCRA, 15 U.S.C. § 1681a(w), as 

follows: 

a consumer reporting agency that compiles and maintains files on consumers on a 

nationwide basis relating to (l) medical records or payments; (2) residential or 

tenant history; (3) check writing history; (4) employment history; or (5) insurance 

claims. 

Central Credit compiles and maintains files on consumers on a nationwide basis that 

relate, inter alia, to consumers' check-writing history. As a nationwide specialty consumer 

reporting agency, Central Credit is subject to, among other sections, 609 and 612 ofthe FCRA, 

15 U.S.C. §§ 1681g and 1681j, and the FTC's Streamlined Process Rule, 16 C.F.R. § 610.3. 

COUNT I -- Violations of Section 607(d) of the FCRA 

12. Section 607(d)(l) of the FCRA, IS U.S.C. § 168Ie(d)(I), requires that a consumer 

reporting agency provide, to any person who regularly and in the ordinary course of business 

furnishes information about any consumer to the consumer reporting agency ("furnisher"), a 

"Notice To Furnishers ofInformation: Obligations of Furnishers Under the FCRA" ("Furnisher 

Notice"), the acceptable content of which is set forth in 16 C.F.R. Part 698, Appendix G. Section 

607(d)(2) of the FCRA, IS U.S.C. § 168Ie(d)(2), requires that a consumer reporting agency 

provide, to any person to whom it provides a consumer report ("users"), a "Notice To Users of 

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Case 2:10-cv-00565 Document 1 Filed 04/20/10 Page 5 of 9

Consumer Reports: Obligations of Users Under the FCRA" ("User Notice"), the acceptable 

content of which is set forth in 16 C.F.R. Part 698, Appendix H. The Furnisher Notices and the 

User Notices inform furnishers and users, respectively, oftheir responsibilities under the FCRA, 

such as a furnisher's responsibility to provide accurate information or a user's responsibility to 

provide adverse action notices. 

13. Prior to 2008, Central Credit failed to provide Furnisher Notices to furnishers or 

User Notices to users. 

14. By and through the acts and practices described in Paragraph 13 above, Central 

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

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

practices alleged in Paragraph 13 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 -- Violations of Section 609(c)(2) of the FCRA 

16. Section 609(c)(2) of the FCRA, 15 U.S.C. § 1681g(c)(2), requires that when a 

consumer reporting agency provides a file disclosure to a consumer, a Summary of Rights be 

provided to the consumer along with each written file disclosure. The acceptable content of the 

Summary of Rights is set forth in section 609(c)(l)(B) of the FCRA, 15 U.S.C. § 1681g(c)(l)(B), 

and the model notice prepared by the FTC is.set forth in 16 C.F.R. Part 698, Appendix F. The 

Summary of Rights informs consumers of their rights under the FCRA, such as the right to 

dispute inaccurate information. 

Page 5 of 9 

Consumer Reports: Obligations of Users Under the FCRA" ("User Notice"), the acceptable 

content of which is set forth in 16 C.F.R. Part 698, Appendix H. The Furnisher Notices and the 

User Notices inform furnishers and users, respectively, oftheir responsibilities under the FCRA, 

such as a furnisher's responsibility to provide accurate information or a user's responsibility to 

provide adverse action notices. 

13. Prior to 2008, Central Credit failed to provide Furnisher Notices to furnishers or 

User Notices to users. 

14. By and through the acts and practices described in Paragraph 13 above, Central 

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

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

practices alleged in Paragraph 13 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 -- Violations of Section 609(c)(2) of the FCRA 

16. Section 609(c)(2) of the FCRA, 15 U.S.C. § 1681g(c)(2), requires that when a 

consumer reporting agency provides a file disclosure to a consumer, a Summary of Rights be 

provided to the consumer along with each written file disclosure. The acceptable content of the 

Summary of Rights is set forth in section 609(c)(l)(B) of the FCRA, 15 U.S.C. § 1681g(c)(l)(B), 

and the model notice prepared by the FTC is.set forth in 16 C.F.R. Part 698, Appendix F. The 

Summary of Rights informs consumers of their rights under the FCRA, such as the right to 

dispute inaccurate information. 

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Case 2:10-cv-00565 Document 1 Filed 04/20/10 Page 6 of 9

17. Prior to 2008, Central Credit failed to provide a Summary of Rights notice that 

contained all of the information required by section 609(c)(l)(B) of the FCRA, 15 U.S.C. 

§1681g(c)(l)(B), as required by section 609(c)(2) of the FCRA, 15 U.S.C. § 1681g(c)(2). 

18. By and through the acts and practices described in Paragraph 17 above, Central 

Credit has violated section 609(c)(2) of the FCRA, 15 U.S.c. § 1681g(c)(2L 

19. Pursuant to section 621(a)(1) ofthe FCRA, 15 U.S.C. § 1681s(a)(l), the acts and 

practices alleged in paragraph 17 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 III - Violations of Sections 612(a)(I)(C) and 612(a)(2) of the FCRA 

and Section 610.3 of the Streamlined Process Rule 

20. Section 612(a)(l)(C) of the FCRA, 15 U.S.C. § 1681j(a)(l)(C), directs the 

Commission to prescribe regulations requiring nationwide specialty consumer reporting agencies 

to establish a streamlined process for consumers to request free annual file disclosures (i. e., 

consumer reports), including a toll-free number for consumers to call to make the request. 

Pursuant to section 612( a)(l )(C), the Commission promulgated the Streamlined Process Rule, 

16 C.F.R. § 610.3, which became effective on December 4,2004. The rule requires, inter alia, 

that nationwide specialty consumer reporting agencies establish a streamlined process that 

"enable[s] consumers to request annual file disclosures by a toll-free telephone number that ... is 

clearly and prominently posted on any website owned or maintained by the nationwide specialty 

consumer reporting agency ... along with instructions for requesting disclosures by any 

additional available request methods[.]" 16 C.F.R. § 610.3(a)(l). 

Page 6 of 9 

17. Prior to 2008, Central Credit failed to provide a Summary of Rights notice that 

contained all of the information required by section 609(c)(l)(B) of the FCRA, 15 U.S.C. 

§1681g(c)(l)(B), as required by section 609(c)(2) of the FCRA, 15 U.S.C. § 1681g(c)(2). 

18. By and through the acts and practices described in Paragraph 17 above, Central 

Credit has violated section 609(c)(2) of the FCRA, 15 U.S.c. § 1681g(c)(2L 

19. Pursuant to section 621(a)(1) ofthe FCRA, 15 U.S.C. § 1681s(a)(l), the acts and 

practices alleged in paragraph 17 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 III - Violations of Sections 612(a)(I)(C) and 612(a)(2) of the FCRA 

and Section 610.3 of the Streamlined Process Rule 

20. Section 612(a)(l)(C) of the FCRA, 15 U.S.C. § 1681j(a)(l)(C), directs the 

Commission to prescribe regulations requiring nationwide specialty consumer reporting agencies 

to establish a streamlined process for consumers to request free annual file disclosures (i. e., 

consumer reports), including a toll-free number for consumers to call to make the request. 

Pursuant to section 612( a)(l )(C), the Commission promulgated the Streamlined Process Rule, 

16 C.F.R. § 610.3, which became effective on December 4,2004. The rule requires, inter alia, 

that nationwide specialty consumer reporting agencies establish a streamlined process that 

"enable[s] consumers to request annual file disclosures by a toll-free telephone number that ... is 

clearly and prominently posted on any website owned or maintained by the nationwide specialty 

consumer reporting agency ... along with instructions for requesting disclosures by any 

additional available request methods[.]" 16 C.F.R. § 610.3(a)(l). 

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Case 2:10-cv-00565 Document 1 Filed 04/20/10 Page 7 of 9

21. Section 612(a)(2) of the FCRA requires consumer reporting agencies to "provide 

a consumer report under paragraph (I)." Section 612(a)(2), therefore, requires nationwide 

specialty consumer reporting agencies to comply with the Streamlined Process Rule adopted by 

the Commission pursuant to section 612(a)(I)(C). 

22. Central Credit has not established the streamlined process required by the 

Streamlined Process Rule, 16 C.F.R. § 610.3, for consumers to request free annual file 

disclosures. Among other things, Central Credit has not clearly and prominently posted the tollfree telephone number for the free annual file disclosures on any website owned or maintained by 

Central Credit. Central Credit also has failed to provide clear and easily understandable 

instructions for requesting free annual file disclosures on its toll-free number. 

23. By and through the acts and practices described in paragraph 22 above, Central 

Credit has violated sections 612(a)(1)(C) and 612(a)(2) ofthe FCRA, 15 U.S.C. §§ 

1681j(a)(1)(C) and 168Ij(a)(2), and section 610.3 of the Streamlined Process Rule, 16 C.F.R. 

§ 610.3. 

THIS COURT'S POWER TO GRANT RELIEF 

24. Section 621 (a)(2)(A) of the FCRA, 15 U.S.C. § 168 I s(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. Central Credit's violations of sections 607(d), 609(c)(2), 

612(a)(1)(C), and 612(a)(2) of the FCRA and of the Streamlined Process Rille, 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 by the 

Debt Collection Improvements Act of 1996, Pub. 1. 104-134, § 31001(s)(1), 110 Stat. 1321-373, 

Page 7 of 9 

21. Section 612(a)(2) of the FCRA requires consumer reporting agencies to "provide 

a consumer report under paragraph (I)." Section 612(a)(2), therefore, requires nationwide 

specialty consumer reporting agencies to comply with the Streamlined Process Rule adopted by 

the Commission pursuant to section 612(a)(I)(C). 

22. Central Credit has not established the streamlined process required by the 

Streamlined Process Rule, 16 C.F.R. § 610.3, for consumers to request free annual file 

disclosures. Among other things, Central Credit has not clearly and prominently posted the tollfree telephone number for the free annual file disclosures on any website owned or maintained by 

Central Credit. Central Credit also has failed to provide clear and easily understandable 

instructions for requesting free annual file disclosures on its toll-free number. 

23. By and through the acts and practices described in paragraph 22 above, Central 

Credit has violated sections 612(a)(1)(C) and 612(a)(2) ofthe FCRA, 15 U.S.C. §§ 

1681j(a)(1)(C) and 168Ij(a)(2), and section 610.3 of the Streamlined Process Rule, 16 C.F.R. 

§ 610.3. 

THIS COURT'S POWER TO GRANT RELIEF 

24. Section 621 (a)(2)(A) of the FCRA, 15 U.S.C. § 168 I s(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. Central Credit's violations of sections 607(d), 609(c)(2), 

612(a)(1)(C), and 612(a)(2) of the FCRA and of the Streamlined Process Rille, 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 by the 

Debt Collection Improvements Act of 1996, Pub. 1. 104-134, § 31001(s)(1), 110 Stat. 1321-373, 

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Case 2:10-cv-00565 Document 1 Filed 04/20/10 Page 8 of 9

the Court is 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 violations occurring on or after 

that date. 

25. Each instance in which Central Credit has failed to comply with sections 607(d), 

609(c)(2), 612(a)(l)(C), or 612(a)(2) of the FCRA, or with the Streamlined Process Rule, 

constitutes a separate violation of the FCRA for the purpose of assessing monetary civil penalties 

under section 621 of the FCRA. Plaintiff seeks monetary civil penalties for every separate 

violation of the FCRA. 

26. Under section 13(b) of the FTC Act, 15 U.S.C. §53(b), this Court is authorized to 

issue a permanent injunction prohibiting Defendant from violating the FTC Act and the FCRA. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff requests that this Court, pursuant to 15 U.S.C. §§ 45(a)(l), 

45(m)(l)(A), 53(b), 1681s, and 1691c, and pursuant to the Court's own equitable powers: 

(I) Enter judgment against Defendant and in favor of Plaintiff for each law violation 

alleged in this Complaint; 

(2) Enter a permanent injunction to prevent future violations of the FCRA, the 

Streamlined Process Rule, and the FTC Act by Defendant; 

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

FCRA and the Streamlined Process Rule as alleged in this Complaint; 

(4) Order Defendant to pay the costs of this action; and 

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

Page 8 of 9 

the Court is 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 violations occurring on or after 

that date. 

25. Each instance in which Central Credit has failed to comply with sections 607(d), 

609(c)(2), 612(a)(l)(C), or 612(a)(2) of the FCRA, or with the Streamlined Process Rule, 

constitutes a separate violation of the FCRA for the purpose of assessing monetary civil penalties 

under section 621 of the FCRA. Plaintiff seeks monetary civil penalties for every separate 

violation of the FCRA. 

26. Under section 13(b) of the FTC Act, 15 U.S.C. §53(b), this Court is authorized to 

issue a permanent injunction prohibiting Defendant from violating the FTC Act and the FCRA. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff requests that this Court, pursuant to 15 U.S.C. §§ 45(a)(l), 

45(m)(l)(A), 53(b), 1681s, and 1691c, and pursuant to the Court's own equitable powers: 

(I) Enter judgment against Defendant and in favor of Plaintiff for each law violation 

alleged in this Complaint; 

(2) Enter a permanent injunction to prevent future violations of the FCRA, the 

Streamlined Process Rule, and the FTC Act by Defendant; 

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

FCRA and the Streamlined Process Rule as alleged in this Complaint; 

(4) Order Defendant to pay the costs of this action; and 

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

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Case 2:10-cv-00565 Document 1 Filed 04/20/10 Page 9 of 9

MANEESHA MITHAL 

Associate Director 

Division of Privacy 

and Identity Protection 

REBECCA E. KUEHN 

Assistant Director 

Division of Privacy 

and Identity Protection 

KATHERINE ARMSTRONG 

MANAS MOHAPATRA 

Attorneys 

Division of Privacy 

and Identity Protection 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. 

Washington, D.C. 20580 

ANNM.RAVEL 

Acting Assistant Attorney General 

Civil Division 

United States Department of Justice 

DANIEL G. BOGDEN 

United States Attorney 

Distr~ct of Nevada J. 

~O) D ~,_~L 0 

Assistant United States Attorney 

333 South Las Vegas Blvd 

Lloyd George Federal Building 

Las Vegas, NV 89101 

Telephone: 702-388-6336 

EUGENE M. THIROLF 

Director 

Office of Consumer Litigation 

KENNETH L. JOST 

Deputy Director 

L 

Tr I Attorney, 

Of We of Consumer Litigation 

Civil Division 

United States Department of Justice 

P.O. Box 386 

Washington, D.C. 20044 

Telephone: 202-307-6154 

alan.phelps@usdoj.gov 

Page 9 of 9 

MANEESHA MITHAL 

Associate Director 

Division of Privacy 

and Identity Protection 

REBECCA E. KUEHN 

Assistant Director 

Division of Privacy 

and Identity Protection 

KATHERINE ARMSTRONG 

MANAS MOHAPATRA 

Attorneys 

Division of Privacy 

and Identity Protection 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. 

Washington, D.C. 20580 

ANNM.RAVEL 

Acting Assistant Attorney General 

Civil Division 

United States Department of Justice 

DANIEL G. BOGDEN 

United States Attorney 

Distr~ct of Nevada J. 

~O) D ~,_~L 0 

Assistant United States Attorney 

333 South Las Vegas Blvd 

Lloyd George Federal Building 

Las Vegas, NV 89101 

Telephone: 702-388-6336 

EUGENE M. THIROLF 

Director 

Office of Consumer Litigation 

KENNETH L. JOST 

Deputy Director 

L 

Tr I Attorney, 

Of We of Consumer Litigation 

Civil Division 

United States Department of Justice 

P.O. Box 386 

Washington, D.C. 20044 

Telephone: 202-307-6154 

alan.phelps@usdoj.gov 

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