NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

KEITH EDWARDS,

Plaintiff,

V.

EQUABLE ASCENT, FNCL, LLC.,

Defendant.

CECCHI, District Judge.

This matter comes before the Court on an unopposed motion by Equable Ascent

Financial, LLC, (“Equable”), pursuant to Federal Rule of Civil Procedure 12(b)(6) to dismiss

Keith Edwards’s (“Plaintiff’) complaint. The Court has considered Equable’s motion made in

support ofthe instant matter and decides the matter without oral argument. Fed. R. Civ. P. 78.

I. INTRODUCTION

Plaintiff brings the instant action under the Fair Credit Reporting Act (“FCRA”), alleging

that Equable failed to provide Plaintiff with prior notice and authorization to place a collection

account number on his personal credit file. 15 U.S.C. § 1681 et. seq. Based on the reasons set

forth below, Equable’s motion to dismiss is granted.

II. FACTUAL AND PROCEDURAL HISTORY

On April 18, 2011, Plaintiff initiated a cause of action against Equable in the Superior

Court of New Jersey, Law Division, Special Civil Part, Union County alleging breach of contract

for failing to provide him with prior notice and authorization to place a collection account

number on his personal credit file. (Compl. 1, 2.) Plaintiff argues that Equable was obligated to

Civil Action No.: 1 1-cv-2638 (CCC)

OPINION

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follow these procedures when reporting outstanding collection debts to credit reporting agencies.

(Compl, ¶ 5, 6-8.) Plaintiff contends that Equable’s alleged failure to follow these procedures

has resulted in: (I) a negative credit rating, (2) denial of credit, and (3) subjection to illegal

collection agency harassment. (Compl. ¶ 6, 10-13.) To redress these harms, Plaintiff seeks the

following: (1) a notice that his debt has been closed or discharged, (2) notice to credit bureaus to

remove their inaccurate reporting in relation to Plaintiffs account, (3) $750.00 in damages, and

(4) in the case of a default judgment, attorney’s fees not to exceed $3,000. (Compl. ¶J 7-8, 1-3.)

On November 21, 2011, Equable removed the case to this Court. Equable moved to

dismiss Plaintiffs complaint on the grounds that: (1) Plaintiffs complaint does not allege any

cause of action against Equable, but instead refers to an entity termed “Illinois;” (2) assuming,

arguendo, that Plaintiff intended to state that Equable committed the alleged violations, the

complaint still fails to state a claim for relief; (3) Plaintiffs complaint does not allege Equable’s

offending actions; (4) Plaintiffs complaint fails to set forth the basis for damages and how

Equable’s conduct is related to Plaintiffs alleged harms. (Def. Mot. to Dismiss, 6.) Equable

now moves to have Plaintiffs complaint dismissed with prejudice in its entirety. Id.

III. STANDARD OF REVIEW

Federal Rule of Civil Procedure 8(a) governs the construction of a complaint mandating

that a claim for relief must contain “a short and plain statement of the claim of the grounds for

the court’s jurisdiction. . . [a] showing that the pleader is entitled to relief. . . [and] a demand for

the relief sought.” Fed. R. Civ, P. 8(a)(l)-(3). Rule 8 governs a complaint’s construction for all

plaintiffs. However, when the plaintiff is proceeding as pro se, the Court construes this rule

liberally. See US. v. Miller, 197 F.3d 644, 648 (3d. Cir. 1999) (noting the Court’s “time

honored practice of construing pro se plaintiffs’ pleadings liberally.”) Recognizing the

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differences in legal sophistication between a pro se litigant and trained legal counsel, the Court

will hold a pro se plaintiffs complaint to a less exacting standard than its counterpart. See

Haines v. Kerner, 404 U.S. 519 (2007).

The Court now turns to Equable’s motion to dismiss. The Court applies the standard of

review related to requests for dismissal pursuant to Federal Rule of Civil Procedure l2(b)(6).

Under this Rule, the Court may dismiss the complaint for failure to state a claim upon which

relief can be granted. In its application, a motion to dismiss “may be granted only if, accepting

all well pleaded allegations in the complaint as true, and viewing them in the light most

favorable to plaintiff, plaintiff is not entitled to relief.” In re Burlington Coat Factory Sec. Litig.,

114 F.3d 1410, 1420 (3d. Cir. 1997) (citing Bartholomew v. Fischl, 782 F.2d 1148, 1152 (3d.

Cir. 1986). Moreover, the Court’s inquiry is “not whether plaintiffs will ultimately prevail in a

trial on the merits, but whether they should be afforded an opportunity to offer evidence in

support oftheir claims.” In re Rockefeller Ctr. Prop., Inc., 311 F.3d 198, 215 (3d. Cir. 2002).

The Supreme Court refined the Rule 12(b)(6) motion to dismiss standard in both Ashcrofl

v. Iqbal, 129 S.Ct. 1937 (2009) and Bell At!. Corp. v. Twombly, 550 U.S. 544 (2007). Twombly

held that, “factual allegations must be enough to raise a right to relief above the speculative

level.” 550 U.S. at 570, Iqbal further refined the degree of factual pleadings to include facts

“that allows the court to draw the reasonable inference that the defendant is liable for the

misconduct.” Iqbai, 129 S.Ct. at 1949.

When assessing a complaint’s appropriateness, the Court distinguishes factual

contentions that allege actions of the defendant that would satisfy elements of the claim asserted

as distinct from “[t]hreadbare recitals of the elements of a cause of action, supported by mere

conclusory statements.” Jqbal, 129 S.Ct. at 1949; Morse v. Lower Merion Sch, Dist,, 132 F.3d.

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902, 906 (3d. Cir. 1997) (holding that Courts will accept well-pled allegations as true, but will

not credit bald assertions or legal conclusions). Furthermore, the Court is “not bound to accept

as true a legal conclusion couched as a factual allegation . . . [and] can choose to begin by

identifying pleadings that, because they are no more than conclusions, are not entitled to the

assumption of truth.” Iqbal, 129 S.Ct. at 1950. The Court may also examine the complaint’s

allegations along with any documents attached to or referenced in the complaint along with

matters of the public record. Pittsburgh v. W. Penn Power flo., 147 F.3d 256, 259 (3d. Cir.

1998); In re Burlington, 114 F.3d at 1426.

When the Court dismisses a complaint pursuant to Rule 12(b)(6), the plaintiff may be

given leave to amend and reassert the claim within a set period of time. In re Burlington, 114

F.3d at 1434; Grayson v. Mayview State Hosp., 293 F.3d 103, 108 (3d. Cir. 2002). Claims may

be dismissed with prejudice, however, if amending the complaint would be futile. Aiston v.

Parker, 363 F.3d 229, 235 (3d Cir. 2004). Here, “futile” essentially means that the complaint

could not be amended to include a legally cognizable claim. In re Burlington, 114 F.3d at 1426

(citing Giassman v. Computervision Corp., 90 F.3d 617, 623 (1st Cir. 1996)).

IV. DISCUSSION

A. The Federal Credit Reporting Act

The Federal Credit Reporting Act was enacted by Congress primarily to protect

consumers. See Gelman v. State Farm Mutual Auto Ins. Co., 583 F.3d 187, 191 (3d. Cir 2009)

(quoting Safeco. Ins. C’o. ofAmerica v. Burr,, 551 U.S. 47, 52 (“Congress enacted [the] FCRA in

1970 to ensure fair and accurate credit reporting. promote effIciency in the banking system, and

protect consumer privacy.”)). Its stated purpose is to “require that consumer reporting agencies

adopt reasonable procedures for meeting the needs of commerce for consumer credit, personnel,

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insurance, and other information in a manner which is fair and equitable to the consumer, with

regard to the confidentiality, accuracy, relevancy, and proper utilization of such information.”

15 U.S.C. 1681(b). Simply stated, Congress enacted the FCRA to preserve consumer privacy

in the information collected and stored by consumer reporting agencies.

The statute places duties on two types of entities — credit rating agencies and “furnishers

of information.” The latter category generally refers to “any entity that reports information

relevant to a consumer’s credit rating—i.e., payment history, amount of debt, and credit limit—

to credit reporting agencies.” Burreil v, DFS Serv. LLC, 753 F, Supp. 2d 438, 446 (D.NJ. 2010)

(citing H.R. Rep. No. 108-396, at 24 (2003) (Conf. Rep.) (“The most common. . . furnishers of

information are credit card issuers, auto dealers, department and grocery stores, lenders, utilities,

insurers, collection agencies, and government agencies.”)).

B. Plaintiff’s Claims Under § 1681s-2(a)

Section 1681 s-2 of the FCRA generally addresses the responsibilities of information

providers to consumer reporting agencies. 15 U.S.C. § 1 681s-2. Subsection (a) of § 168 ls-2

places a duty on data furnishers to provide accurate information noting that “a person shall not

furnish any information relating to a consumer to any consumer reporting agency if the person

knows or has reasonable cause to believe that the information is inaccurate.” 15 U.S.C. § 168 is2(a). However, this prohibition does not apply if the data furnisher “clearly and conspicuously”

noted an address where consumers can send complaints related to inaccurate charges. 1 5 U.S.C.

168 ls-2(a)(i)(C). Therefore, the FCRA places the burden of the information’s accuracy on the

consumer. If the consumer fails to place the data furnisher on notice that their acquired

information contains inaccuracies, the data furnisher can still provide credit agencies with that

inaccurate information Put simply 1681 s-2(a) enables a data furnisher to pros ide information

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to a consumer credit agency as long as (1) the furnisher has indicated an address to which

consumers can voice their dispute and (2) the furnisher was not in receipt of a complaint related

to the data at issue.

Subsection (a) of 1681 s-2 does not provide a private right of action. In Huertas v. Galaxy

Asset Mgrnt., 641 F.3d 28, 34 (3d Cir, 2011), the court held that a pro se plaintiff could not bring

an action against a data furnisher for transmitting his credit information to a debt collection

agency because “no private right of action exists under that provision [15 U.S.C. § 168 is

2a( 13(A)].” Likewise, in Burrell, 753 F. Supp. 2d at 447-48, this Court acknowledged that 15

U.S.C. § 168 ls-2a(1)(A) contains no provision for bringing a private action. In that case, the

Plaintiff, a victim of identity theft, claimed that after informing his credit card company of his

situation, the company transmitted his information to various credit reporting agencies noting

that the Plaintiff was delinquent in paying his bills. Id. at 439. The Court dismissed Plaintiffs

claim as it related to the FCRA noting that “Mr. Burrell’s claims under subsection (a) of 15

U.S.C. § 168 ls-2 fail because that portion of the FCRA does not provide a private cause of

action,” Id. at 447.

Similarly, in Lorenzo v. Palisades collection, L.L.c., No. 05-0886, 2006 U.S. Dist. WL

891170, at *2 (D.N.J. Apr. 5. 2006), a pro se Plaintiff alleged that a Defendant collection agency

violated the FCRA by fuiling to report to consumer credit agencies that a dispute over Plaintiffs

debt existed and were deficient in failing to update and correct information related to that debt

pursuant to its obligation under § 1681s-2. The Court dismissed plaintiffs claims related to §

1681 s-2(a), “because this subsection does not allow for a private cause of action.” Lorenzo,

2006 WL 891170, at * 2; see also Fino v. Key Bank ofNew York, No, 00-375. 2001 WL 849700,

at *4 (W.D. Pa. July 27, 200l) chiang v. New England Inc., 595 F.3d 26, 35 (1st Cir. 2009)

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(holding that “Congress expressly limited furnishers’ liability under §168 1 s-2(a) by prohibiting

private suits for violations of that portion of the statute”); Gorman v, Wolpoff& Abramson, 584

F.3d 1147, 1162 (9th Cir. 2009) (“[Plaintiff] has no private right of action under § 168 ls-2(a)(3)

to proceed against [a data furnisher] for its . . . failure to notify the [credit reporting agencies]

that he disputed the. . . charges [at issue].”).

Here, Plaintiffs complaint alleges that “Illinois [Equable Ascent Financial LLC] failed to

provide Plaintiff with prior notice and their authorization to place a collection account number

44978 notation on my personal credit file. Illinois did not comply with the requirements

contained in contract, agreement, law, or regulation. Illinois was legal/v required to follow these

procedures when reporting delinquent collection debts to credit reporting agencies.” (Compl. ¶

5, 7-9) (emphasis added). The Court finds that these allegations implicate Equable’s duties as a

data furnisher under 15 U.S.C. § 1681s-2. See carney v. Experian Infi. Solutions Inc., 57 F.

Supp. 2d 496, 502 (W.D. Tenn. 1999) (finding that a furnisher of credit information is an entity

that “transmits information concerning a particular debt owed by a particular consumer to

consumer reporting agencies such as Experian, Equifax, MCCA, and Trans Union.”)

Plaintiffs complaint fails, however, to allege facts showing that Equable breached the

FCRA requirements. See Twomblv, 127 S,Ct, at 1974. Plaintiff does not explicitly cite the

FCRA provisions in his complaint. Plaintiff asks this Court to enforce Equable’s duty to provide

Plaintiff with notice and authorization before placing a notation on his personal credit file

consistent with a legal obligation. Moreover, Plaintiff asserts that he is willing “to dismiss his

complaint” if Equable provides “notice to the credit bureaus to remove their inaccurate reporting

in relations to [his] account.” (Compi. ¶ 7, 16-17.) As discussed above, however, 15 U.S.C. §

1 681s-2(a) does not provide a private right of action to enforce a data furnisher’s duty to report

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accurate information, Plaintiff’s claim under this subsection is therefore dismissed with

prejudice.

C. Plaintiffs Claims Under 15 U.S.C. § 1681s-2(b)

Section 1681 s-2(b) applies to a data furnisher’s actions after being placed on notice by a

consumer rating agency of a dispute and the existence of an informational error is confirmed.

Section 168 ls-2(b) is triggered only after a consumer notifies the consumer credit agency of a

dispute. The consumer credit agency will then notify the data furnisher of the disputed

information within five business days from the time the agency was notified by the consumer.

Section 1681 s-2(b)( 1) provides specific guidelines for how the data furnisher may conduct the

subsequent investigation into remedying the situation. 15 U.S.C. § 168 is-2b)(l) states:

After receiving notice pursuant to section 1681 i(a)(2) of this title of a dispute with

regard to the completeness or accuracy of any information provided by a person

to a consumer reporting agency, the person shall--

(A) conduct an investigation with respect to the disputed information;

(B) review all relevant information provided by the consumer reporting agency

pursuant to section 1681 i(a)(2) of this title;

(C) report the results of the investigation to the consumer reporting agency:

(D) if the investigation finds that the information is incomplete or inaccurate,

report those results to all other consumer reporting agencies to which the person

furnished the information and that compile and maintain files on consumers on a

nationwide basis; and

(E) if an item of information disputed by a consumer is found to be inaccurate or

incomplete or cannot be verified after any reinvestigation under paragraph (1),

for purposes of reporting to a consumer reporting agency only, as appropriate,

based on the results of the reinvestigation promptly-

(i) modify that item of information;

(ii) delete that item of information: or

(iii) permanently block the reporting of that item ofinformation.

A data furnisher’s investigation of its records must be reasonable “to determine whether the

disputed information can be verified,” Kra/ewki v. American Honda Fin, corp.. 557 F. Supp.

2d 596, 609 (E.D. Pa. 2008) (quoting Johnson v. MBNA Am. Bank, NA, 357 F.3d 426, 431 (4th

Cir. 2008)). It is important to emphasize that § 168 ls-2(b) does not provide relief for consumers

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who lodge their dispute directly with their credit card company. See Burreli, 753 F. Supp. 2d at

448. Instead, the consumer is obliged to contact the consumer credit rating agency of the dispute

that then contacts the consumer’s credit card company. See Young, 294 F.3d at 639.

This Court has recognized the existence of a private right of action pursuant to 15 U.S.C.

§ 1681s-b(2). See Martinez v. Granite State 1gmt. & Res., No. 08-2769, 2008 U.S. Dist. WL

5046792, at *5 (D.N.J. Nov. 20, 2008)(citing Krajewski, 557 F. Supp. 2d at 608)); Bartley v.

LVNVFundingLLC., No. 09-3884. 2010 U.S. Dist. WL 2629072. at *9 (D.NJ. June 28, 2010).

“[1]n order to state a claim under section 168 ls-2(b), the plaintiff must allege that: (1) she sent

notice of disputed information to a consumer reporting agency, (2) the consumer reporting

agency then notified the defendant furnisher of the dispute, and (3) the furnisher failed to

investigate and modify the inaccurate information,” Rz4J v. America Servicing Co., No. 07-

0489. 2008 U.S. Dist. WL 1830182, at *4 (W.D. Pa. Apr. 23, 2008); see also, Smith v.

Citimortgage, Inc., No. 08-492, 2009 U.S. Dist. WL 1976513 (S.D. Ms. July 7, 2009); Shulick v.

Experian, No. 11-3809, 2011 U.S. Dist. WL 4346335 (E.D. Pa. Sept 16, 2011).

The existence of a private right of action under subsection (b) hinges on the consumer’s

direct notification of a dispute to the consumer credit agency. As this Court pointed out in

Burrell, “[a] consumer cannot maintain a claim under subsection (b) of 15 U.S.C. c,S 1681-s2

based on disputes filed directly with his or her credit card company. Rather the consumer must

communicate such disputes to a credit rating agency which is then obligated to pass them on to

the credit card company.” Burrell, 753 F. Supp. 2d at 448 (citing Young. 294 F.3d at 639).

When a plaintiff alleges contact with a consumer credit agency, Courts in this Circuit have

usually permitted complaints to proceed on the premise that discovery is warranted to ascertain

whether or not a claim actually exists. See Kra/ewski, 557 F. Supp. 2d. at 610; Jaramillo v.

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Experian Info. Solutions, Inc., 155 F. Supp. 2d. 356, 363 (ED. Pa. 2001); Ruff 2008 WL

1830182, at *4

Here, Plaintiff’s complaint fails to allege that he notified a consumer agency of disputed

information. See Ru/f 2008 WL 1830182, at *4 The complaint argues that “Illinois [Equable

Ascent Financial] failed to provide Plaintiff with prior notice and their authorization to place a

collection account number 44978 notation on [his] personal credit file,” (Compl. ¶ 5, 3-4.) Even

when construed liberally, the Plaintiff’s complaint makes no mention of any attempt on his part

to contact a consumer credit agency regarding his dispute over Equable’s placement of collection

account number 44978 notation on his credit file. Since such an allegation is necessary to

maintain a private right of action under § 1681 s-2(b), the Court need not reach the other two

prongs highlighted in Rtff Therefore, Plaintiff’s claims under 15 U.S.C. § 1681s-2(b) are

hereby dismissed. Erikson v. Fardus, 551 U.S. 89 (2007). Plaintiff may, however, submit an

amended complaint to correct any deficiencies in this claim, in accordance with this Opinion.

U. Pre-Eniption of State Law under the FCRA

The FCRA contains two principal provisions that effectively pre-empt most, if not all,

state causes of action. 15 U.S.C. § 168 ih(e) states:

Except as provided in sections 168 in and 16810 of this title, no consumer may bring any

action or proceeding in the nature of defamation, invasion of privacy, or negligence with

respect to the reporting of information against any consumer reporting agency, any user

of information, or any person who furnishes information to a consumer reporting agency.

based on information disclosed pursuant to section 1 681g, 168th, or 168 Im of this title,

or based on information disclosed by a user of a consumer report to or for a consumer

against whom the user has taken adverse action, based in whole or in part on the report

except as to false information furnished with malice or willful intent to injure such

consumer.

The FCRA’s second pre-emption statute, 15 U.S.C. § 1681 (t)(b)(1 )(F), states that “no

requirement or prohibition may be imposed under the laws of any State - - (1) with respect to any

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subject matter regulated under — (F) section 168 Is-2 of this title, relating to responsibilities of

persons who furnish information to consumer reporting agencies.” Based on the language of the

statute, section 168 l(t)(b)(i)(F) pre-ernpts all state causes of action, while 15 U.S.C § 168 lh(e)

provides pre-emption exemptions for defamation, invasion of privacy, and negligent actions

involving a data furnisher acting with malice or willful intent.

This Court has adopted a total pre-emption approach. Most notably, Burreil held that §

168 l(t)(b)(i)(F) “leaves no room for state law claims against furnishers of information

regardless of whether those claims are couched in terms of common law or state statutory

obligations.” Burrell, 753 F. Supp. 2d at 451. Similarly, both Nonnenmacher v, capital One,

2001 WL 1321710 (D.N.J. Mar. 31, 2011) and Hende,on v. Equable Ascent Fin. LLC’., 2011

WL 5429631 (D.N.J. Nov. 4, 2011) adopted the total preemption approach by dismissing a

plaintiffs state statutory and common law claims. See also, Cosmas v. Am. Express Centurion

Bank, 757 F. Supp. 2d 489, 479-501 (D.N.J. 2010); Bartley v. LVNV Funding, LLC’,, 2010 U.S.

Dist. WL 2629072, at *4 (D.N.J. June 28, 2010); DiMedio v. HSBC Bank, Civ. A. 08-

552l(JBS/KMW), 2009 U.S. Dist. WL 1796072, at *9 (D.N.J. June 22, 2009). Moreover, the

scope of section 168 i(t)(b)(l)(F)’s pre-emptive effect is clear from the text: “[n]o requirement

or prohibition’ relating to the duties of furnishers of information ‘may be imposed under the laws

ofanv State.” 15 U.S.C. § 1681(t)(b)(1)(F).

This approach is also consistent with the Supreme Court’s holding in Cipollone v. Liggett

Gip. Inc., 505 U.S. 504. 521 (1992), which thund that the statute’s usage of”no requirement or

prohibition” is to he construed broadly, “suggest[ing} no distinction between positive enactments

and common law to the contrary, those words easily encompass obligations that take the form of

common-law rules.” See Premium Mortg. corp. v. Equifzx, Inc.. 583 F.3d (2d Cir. 2009)

ii

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(adopting total preemption approach and reiterating the Supreme Court’s interpretation of “no

requirement or prohibition”). Finally’, a total pre-emption approach to § 1681(t)(b)(1)(F) is

consistent with this statute’s legislative history. In this regard, “Congress’s main goal in

enacting the statute was establishing uniform regulations for furnishers; this purpose would be

frustrated by an interpretive approach which leaves state common law claims against furnishers

unaffected.” Henderson, 2011 WL 5429631 at *5 (citing CONG. REC. H8, 122-2 (2003);

Jaramillo, 155 F. Supp. 2d at 361).

Therefore, any of Plaintiff’s breach of contract and negligence claims related to

Equable’s alleged failure to provide the Plaintiff with notice or authorization in placing a 44978

notation on his personal credit file are pre-empted by § 168 i(t)(b)(1)(F) of the FCRA, which

prohibits both state statutory and common law causes of action against data furnishers of

consumer credit information. Plaintiff’s state common law claims are thereby dismissed with

prejudice.

V. CONCLUSION

For the reasons stated above, Defendant’s motion to dismiss the Complaint is granted,

To the extent that Plaintiff can amend his Complaint in accordance with this decision, Plaintiff is

granted twenty-one (21) days in which to file an Amended Complaint that cures the pleading

deficiencies discussed below, An appropriate form of Order will accompany this Opinion.

DATED: April 16, 2012

ç) 4

CLAIRE C. CECiT, USJ.J.

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