Plaintiff, COMPLAINT FOR RELI$F

AND WONETAR DAMAGES

Vs,

JURY DFMAND ENI)ORSED

LEXISNEXIS

DIVISION OF RF,LX PLC

230 Park Avenue - Floor 7New York, New York 10169

EQUIF.AX CREDIT INFORMATION SERVICES, INC.

1550 Peachtree Street NW

Atlanta, Georgia 30309

EXPER?AN }NFORMAT?ON SOLUTIONS, INC.

29 Broadway

Sixth FloorNew York, New York 10009

TRANSUNION INTERMEDIATE HOLDKNGS, INC.

555 W. Adams Street

Cliicago, Il?inois 60661

Defendants.

COMPLAINT

$c,14go'qqd l.n'foryationPlaintiff Michae? J. Young (hereinafter '4Young") is an individual residing in Colurnbus, Ohio and is involved in various business activities whereby he seeks financing and credit from Banks, Lenders and other entities.

Defendants RELX PLC LexisNexis (hereinufter ?LexisNexis"), Eqiiifav Credit Information Servtces, Inc. (hereinafter 4'Equifax"), Experian Information Solutions, Inc. (hereinafter "Experian") and TransUnion Intermediate Holdings, Inc. (hereinafter '4TransUnion") supply credit and regal research ird'ormation data to Banks, Lenders and other eredtt granting entities.
entities that do business in the State of Oliio and are duly qualified to do business in

Ohio.

JQFJS?!)]!CTION 4ND VE,q?UE

3. Tlie Court has jurisdiction over this action pursuant to O.R.C. 2305.01.4. Venue is proper pursuant to the Ohio Rules o'f' Civil Procedure Sections 3(B)(3) and

3(B)(6) among others.

COUNTI

s. R?U'LX PLC LexisNexis (hereinafter ?LexisNexis") has reported erroneous

information on Plaintiff Michael J, Young (hereinafter '4Young") to Equifax Credit

Information Services, Inc. (hereinnfter '4Equifax") and Experian Informatton

Soluttons, Inc. (liereinafter ?Experian") and TransUnion Intermediate Holdings, Inc.

(hereinnfter "TransUnion"). Said erroneous information includes the following items:

a) United States Bankruptcy Court-Southern Distriet Of Ohio Case No. 15-S40'l5,

wherein LexisNexis reported that the Petitioner was Plaintiff oung as a

"Personal Filer' instead of his status in the filing only in his capacity as a"Trustee". LexisNexts has erroneously reported to Equffax, F.ixperian and

TransUnion that this filing was a ?Personal Bankruptey" of Young and,
"Personal Filer' instead of hjs status in the filing only in his capacity as a

4'Trustee". LexisNexjs has erroneously reported to Equifax, Experian and

TransUnion that this filing was a '&Personal Bankruptcy" of Young and,

thereafter, Equifax, Experian and TransUnion issued credit reports nottng thnt

this was a "personal Bankruptcy" of Young.

e) United States Bankruptey Court-Southern District Of Ohio Case No. 16-53726,

wherein LexisNexis reported that the Petitioner was Plaintiff Young as a

"I)ersonal Filer' instead of his status in the fi?ing only in his capacity as a"Trustee". LexisNexis has erroneously reported to Equifax, Experian and

TransUnion that this filjng was a "Personal Bankruptcy" of Young and,therea'fter, Equifax, Experian and TransUnjon issued credit reports noting thatthis was a "personal Bankruptcy" of Young.

d) A Federal Tax Lien filed In Fairfield County, Ohio, Lien No. 201500006068, in

tbe a'inount of $53,467, filed of reeord tn April, 2015 and still valid. LexisNexishas erroneously reported to Equifax, Experjan and TransUnion that this hen is

still of reeord and not released, and, thereafter, Equifax, Experian andTransUnion issued credit reports noting that this was an ?unpaid tax lien" of

Young and stiil of record.

e) A ]Federal l'ax Lien filed In Franklin County, Ohio, Lten No. 201509101286, in

the amount of $20,796, filed ot record in Septmnber, 2015 and stijl valid.

LexisNexis has erroneously reported to Equffax, Experian and TransUnion
6. Dej'endant Young has repeatedly contacted LexisNexis* by tejephone conversations

and in writing, about the error in reporting these items set forth in a, b, c, d and eabove, and other erroneous information, to Equifax, Experjan and TransUnion.

LexisNexis has refused to correet its erroneous reporting and continues to report, in a

'Greckless" arid €'arrogant" manner, thu incorrect information, in deference to

Plaintiff Young's requests for corrections. The reporting and issuance of this

erroneous information has damaged the reputation oi' Plaintiff Young and his abtlity

to get credit from Banks and Lenders.

GOUN"I' Il

7. Plaintiff Young hereby incorporates and restates the above paragraphs as if fully

rewritten herein.

8. Defendant Equifax has used the erroneous information from LexisNexis 011 credit

reports it has issued on Plaintiff Young, and Young has repeated?y contacted Equifax,

in writing and by e-mail eorrespondence, about the error in reporting this erroneous

and incorrect information. Equifax has refused to correct its erroneous reporting andcontinues to report, in a 46reckless" and <'arrogant" manner, this ineorrect

tnf'orniation, in det'erence to Pjaintiff Young's requests for corrections. The

reporting and issuance of this erroneous information by Equifax has damaged the

reputation of Plaintiff Young and hts ability to get credit from Banks and Lenders.
applications, Young has never authorized Equifax to issue any cred*t report or rating

of hb credit to any entity or individual. This reporting of Plaintiff Young's credithistory and a rating, whether accurate or erroneous, is illegal and an 'invasion of

privacy' of Young's rights, both under Ohio and United States law, and the issuance

of said repor€s and ratings have damaged Young and his abuity to do business,

COUNT m

10. Plaintiff Young hereby incorporates and restates the above paragraphs as ff fully

rewritten herein.

11. Defendant Experian has used the erroneous informmtion from LexisNexis on eredit

reports it bas issued on Plaintiff Young, and Young has contacted Experian about the

error in reporting this erroneous and incorrect information. Experian has refused to

correet its erroneous reporting and continues to report, in a '4reckless" and

'4arrogant" manner, this incorrect information, in deference to Plaintiff Young's

requests for corrections. The reporting and issuance of thSs erroneous information by

Experian hns danxaged the reputation of Plaintiff Young and his ability to get creditfrom Banks and Lenders.

12. In addition to the tortious behavior by Defendant Experian set forth above, Experian

bas issued credit inj'ormation and a 4eredit score' or 'credit rating' on Plaintiff Young

to various companies that make loans or advance eredit tn indiv!dnals such as Young.

Except for sotne written authorizations given by Young for speci'flc credit
of said reports and ratings have damaged Young and his ability to do business.

CQUNT IV

13, Plaintiff Young hereby ineorporates and restates the above paragraphs as if fully

rewritten herein,

14. Defendant TransUnion has used the erroneous information froxn LexisNexis on credit

reports it has iSsued on Plaintiff )'oung, and Young has repeated?y contacted

TransUnion, ixi writing and by e-mail correspondence, about the error in reporting

this erroxieous and incorreet information. TransUnion Iias refused to correct its

erroneous reporting and continues to report, in a "rec!dess" and 44arrogant" manner,this incorrect tnformat*on, in deference to ]!aintiff Young's requests for corrections.

The reporting and issuance of this erroneous jnformation by TransUnion hasdamaged the reputation of Plaintiff Young and his abiJity to get credit from Banks

and Lenders.

15. In addition to tbe tortious behavjor by Detendant TransUnion set forth above,

TransUnion has issued credit information and a 'credit score' or 'credit rating' on

Plaintiff Young to various companies that make loans or advance credit to individuals

such as Young. Except J'or some written authorizations given by Young for speeificcredit applications, Young has never authorized TransUnion to issue any credit report

or rating of his credit to any entity or individual. This reporting of Plaintiff Young's

credit history and a rating, whether accurate or erroneous, is H?egal and an 'invasion
RELX PLC LexisNexis, Equifax Credit Information Serviees, Inc@, Experian

Information Solutions, Inc. mnd TransUnion Intermediate Holdings, Inc., joint?y and

severally, and for the relief as follows:

A. As to Count I, an Order of the Court that t) direets LexisNexis to delete all

information as set forth in Paragraphs s. a), b), c), d) and e) of this Complaint as

to erroneous inf'ormation it is reporting; ii) to notify Defendants Equifax,

Experian and TransUnion to delete thjs erroneous information from all credtt

reports of Plaintiff Young; iii) to issue a letter of correction direeted to all entitiesthat Plaintiff Young provides to LexisNexts regarding said erroneous

information as set forth in said Paragraphs s. a), b), c), d) and e) of this

Complaint ; iv) for a monetary judgment mgainst LexsisNexis in favor of Plaintiff

Young for compensatory damages in the amount of $500,000.00 and for a

monetary judgment against LexisNexis in favor of Plaintiff Young for punitive

damages in the amount of $1,500,000.00.

B. As to Count II, an Order of the Court that i) directs Equil'ax to delete all

information as set forth in Paragraphs s. a), b), c), d) and e) of this Complaint asto erroneous information it is reporting in credit reports on Plaintiff Young; u)

to jssue a letter of correction directed to all entities that Plaintiff Young provides

to Equifax regarding said erroneous information as set forth in said Paragraphs

s. a), b), c), d) and e) of this Complaint; iii) to refrain from issuing to any person

or entity, without the express consent of Plaintiff Young, any and all eredit
amount of Sl,500,000.00.

C. As to Count III, an Order of the Court that i) directs Experian to delete all

bif'ormation as set forth in Paragraphs s. a), b), c), d) and e) of this Comp}aint as

to erroneous information it is reporting in credtt reports on Plaintiff Young; ti)

to issue a letter of correction directed to all entities tbat P?aintiff Young provides

to Experian regarding satd erroneous information as set t'ortli in said Paragrnphs

s. a), b), e), d) and e) of this Comp)aint; iii)to refrain trom issuing to any person

or entity, without the express consent of P?aintiff Young, any and all credit

reports, credit ratings and credit scores regarding Plaintiff Young, and; iv) for a

monetary judgment against Experian in favor of PJaintiff Young for

compensatory damages in the amount of $500,000.00 and for a monetary

judgment against Experian in favor of Plaintiff Young for punitive damages inthe amount of $1,500,000.00.

D. As to Count IV, an Order of the €ourt that i) directs TransUnion to delete all

information as set forth in Paragraphs s. a), b), c), d) and e) of this Complaint as

to erroneous information it is reporting in credit reports on Plaintiff Young; ii)

to issue a letter of correction directed to a?l entities thnt Plaintiff Young provides

to TransUnion regarding said erroneous information as set forth in said

Paragraphs s. a), b), c), d) and e) of this Complaint; iii) to refrain from issuing to

any person or entity, without the express eonsent of Plaintiff oung, any and all

credit reports, credit ratings and credit scores regarding Plaintiff Young, and;
E. Payment of all of Plajntiff Young

s attorney fees, court costs and any and all of

his expenses reJated to this aetion. And,

F. For such other legal and equitable relief to which Plaintiff Young may be

entitled.

')'Z'hL-J" ./..)- M"-w

'?'siel J. Youn', (

1)R(') SE ' ,610 0ld Farm Road

Co?umbus, Ohio 43213E-Mail: niyoun.gi@vo.uprop.con'4

Telephone: (614) 861-1000