 On or about December 15, 2014, Ms. Connolly applied for employment with  Umpqua in Seattle, Washington.     As part of the application process, Ms. Connolly was directed to sign a  document that purported to be a combination disclosure and authorization to procure a  background check on Ms. Connolly. A copy of this form is attached as Exhibit A. The  document states that the background investigation may include criminal convictions, motor  vehicle and other reports, as well as records relating to credit, and information relating to  character, work habits, and employment.    Ms. Connolly brings these claims on behalf of a class, pursuant to Fed. R. Civ.  P. 23.    The class consists of: (a) all individuals; (b) who applied for employment with  Umpqua, or were employed by Umpqua; (c) about whom Umpqua obtained a consumer report  for employment purposes during the Class Period; (d) who completed a disclosure and  authorization form that was not a stand alone document, and was not clear and conspicuous.     By including additional language, questions, blanks, and disclaimers in its  consumer report disclosure and authorization form that Plaintiff and other class members were  required to execute, Umpqua violated 15 U.S.C. § 1681b(b)(2)(A)(i) of the FCRA.    Umpqua’s disclosure and authorization form was not “clear and conspicuous”  and it did not consist solely of the disclosure that a consumer report may be obtained for  employment purposes, in violation of 15 U.S.C. § 1681b(b)(2)(A)(i) of the FCRA.    Umpqua’s actions were willful. Umpqua knew or should have known that its  disclosure form should consist solely of the disclosure, and not include extraneous information  or questions.     Ms. Connolly and class members are entitled to statutory damages of not less  than $100, and not more than $1,000 for each violation of the FCRA, pursuant to 15 U.S.C. §  1681n(a)(1)(A).    Ms. Connolly and class members also seek punitive damages, attorneys’ fees  and costs, pursuant to 15 U.S.C. § 1681n(a)(2).    Umpqua violated 15 U.S.C. § 1681b(b)(2)(A)(ii) by procuring consumer reports  for employment purposes without first obtaining valid authorizations from Ms. Connolly and  class members.    Umpqua’s violations of the FCRA in this regard were willful. Umpqua knew or  should have known that its authorization form was not valid.    Umpqua violated 15 U.S.C. § 1681m(a)(2), (3) by failing to provide subclass  members with the name, address, and telephone number of the entity that provided the  consumer report to them, and to provide a numerical credit score.     Umpqua’s actions were willful. Umpqua knew or should have known that it did  not provide a copy of the disclosures required after taking adverse action.     Ms. Connolly and members of the subclass seek statutory damages of not less  than $100 and not more than $1,000 for each such violation, pursuant to 15 U.S.C.  § 1681n(a)(1)(A).     Ms. Connolly and members of the subclass also seek punitive damages,  attorneys’ fees and costs for this violation, pursuant to 15 U.S.C. § 1681n(a)(2).    Sterling violated 15 U.S.C. § 1681b(b)(3) by failing to notify job applicants  prior to its taking adverse action based in whole or in part on information contained in their  consumer report.     Sterling violated 1681m(a) by failing to provide subclass members with adverse  action notices after it took adverse action against them.    FAILURE TO PROVIDE ADVERSE ACTION DISCLOSURES ON BEHALF OF  STERLING ADVERSE ACTION SUBCLASS  15 U.S.C. §§ 1681b(b)(3); 1681m(a)(2), (3)   FAILURE TO PROVIDE ADVERSE ACTION DISCLOSURES ON BEHALF OF  UMPQUA ADVERSE ACTION SUBCLASS  15 U.S.C. § 1681m(a)(2), (3)   FAILURE TO OBTAIN PROPER AUTHORIZATION BEFORE PROCURING A  CREDIT REPORT IN VIOLATION OF 15 U.S.C. § 1681b(b)(2)(A)(II)   FAILURE TO PROVIDE A CLEAR, CONSPICUOUS, AND STAND-ALONE  DISCLOSURE IN VIOLATION OF   15 U.S.C. § 1681b(b)(2)(A)(I)  