 Defendant is one of the nationwide credit reporting companies in the United States. 1    Defendant sells consumer Credit Reports to millions of American consumers  annually.    Defendant is a consumer reporting agency (“CRA”) that compiles and maintains  files on consumers on a nationwide basis and, as such, is regulated by the FCRA. See 15 U.S.C. §  1681a(f), (p).    One purpose of the FCRA is to require consumer reporting agencies to “adopt  reasonable procedures for meeting the needs of commerce for consumer credit, personnel,  insurance, and other information in a manner which is fair and equitable to the consumer.” 15  U.S.C. § 1681(b).    In furtherance of this goal, the FCRA mandates that Defendant, upon request, shall  clearly and accurately provide to a consumer all information in the consumer’s file at the time of  the request. 15 U.S.C. § 1681g(a)(1). In addition, when the request is made through the FCRA’s  Centralized Source, Defendant is required provide a consumer with a free copy of their Credit  Report each year. 15 U.S.C. § 1681j(a)(1)(A).     The only requirement for a consumer to obtain his or her file disclosure or free  report is that the consumer provide “proper identification.” 15 U.S.C. § 1681h(a)(1).    Plaintiff repeats each and every allegation contained in the paragraphs above and  incorporates such allegations by reference herein.    Pursuant to 15 U.S.C. §§ 1681n and 1681o of the FCRA, Defendant is liable for  willfully and negligently failing to provide consumers such as Plaintiff with a disclosure of all  information in their consumer files at the time of the request, following the furnishing of proper  identification, in violation of 15 U.S.C. § 1681g(a). Specifically, Plaintiff and the Class members  provided proper identification as required by 15 U.S.C. § 1681h(a)(1), but were denied the  information in their file.    As a result of Defendant’s practices, Plaintiff and the Class members have suffered  damages in the form of payment of the fees described above.    Plaintiff repeats each and every allegation contained in the paragraphs above and  incorporates such allegations by reference herein.    Pursuant to 15 U.S.C. §§ 1681n and 1681o of the FCRA, Defendant is liable for  willfully and negligently failing to provide consumers such as Plaintiff with their free annual credit  reports and file disclosures free of charge following the furnishing of proper identification through  Centralized Source, in violation of 15 U.S.C. § 1681j. Specifically, Plaintiff and the Class members  provided proper identification as required by 15 U.S.C. § 1681h(a)(1), but were denied their free  reports and instead required to pay for reports that should have been free of charge.    As a result of Defendant’s practices, Plaintiff and the Class members have suffered  damages in the form of payment of the fees described above.    As a result of Defendant’s acts and practices as alleged in this Class Action  Complaint, Plaintiff, on behalf of himself and all Class members, seeks actual, statutory, and  punitive damages, in an amount to be proven at trial. Plaintiff, on behalf of himself and all Class  members, additionally seeks costs and reasonable attorney’s fees.     THEREFORE, Plaintiff prays for relief as set forth below.   Plaintiff repeats each and every allegation contained in the paragraphs above and  incorporates such allegations by reference herein.    Plaintiff repeats each and every allegation contained in the paragraphs above and  incorporates such allegations by reference herein.    This cause of action is brought pursuant to the CLRA, seeking injunctive and  monetary damages.    Defendant’s actions, representations, and conduct have violated, and continue to  violate, the CLRA because they extend to transactions that are intended to result, or which have  resulted, in the sale or lease of goods or services to consumers.    Plaintiff and the Class members are “consumers” as that term is defined by the  CLRA. See CIV. CODE § 1761(d).    Plaintiff repeats each and every allegation contained in the paragraphs above and  incorporates such allegations by reference herein.    Plaintiff brings this claim for violation of the CCCRAA individually and on behalf  of the California Subclass.    Defendant is a “consumer credit reporting agency” as defined by the CCCRAA.  See CIV. CODE § 1785.3(d).    Plaintiff and the California Subclass members are “consumer[s]” as defined by the  CCCRAA. See id. § 1785.3(b).    The above-referenced Credit Reports are “consumer credit reports” as defined by  the CCCRAA. See id. § 1785.3(c).   A.  Defendant Is Required to Provide a Free Credit Report to   Plaintiff and the Members of the Class   Unfair and Unlawful Business Acts and Practices,  In Violation of Business and Professions Code Section 17200 et seq.  On Behalf of the Class   Violation of the California Consumer Credit Reporting Agencies Act,  CIV. CODE § 1785.1 et seq.  On Behalf of the California Subclass   Violation of the Consumers Legal Remedies Act – CIV. CODE § 1750 et seq.  On Behalf of the Class   Violation of the Fair Credit Reporting Act – 15 U.S.C. § 1681j  On Behalf of the Class   Violation of the Fair Credit Reporting Act – 15 U.S.C. § 1681g(a)  On Behalf of the Class  