 During the call, Plaintiff was never informed that he may have his credit pulled,  nor was Plaintiff informed of any reason that Cox would be pulling his credit.     After learning of the pull, Plaintiff mailed Cox a letter stating that the inquiry was  not authorized and requesting that Cox have the inquiry removed. Cox took no action in  response to this letter, leaving Plaintiff with an unauthorized hard inquiry on each of his  three credit reports.     This is not the first time that Cox has made an unauthorized “hard inquiry.”      One consumer on FicoForums has written:   So a Cox communications salesman was coming door to door looking for  business. He offered me a great deal on internet service and I'm fed up with  my slow at&t dsl. I filled out no paperwork or application the guy just took  my info and went to his car to set up the install. Today I get the Fico alert  that I had an inquiry on 10/2 by cox communications. I'm assuming this is a  hp. Do I have any recourse? they never told me they were going to do a hp  and if they did I would have declined their offer.1    Plaintiff’s experience, along with the above publicly available information,  demonstrates that Cox has a habit of performing unauthorized inquiries on consumers’  credit reports.    Upon information and belief, Defendant instructs its agents to request  identification information from consumers prior to providing information about the  availability and pricing of services.     Defendant does not notify consumers that upon providing identifying information,  Defendant will perform a credit inquiry on his or her credit report.     Defendant’s practice causes real and concrete injury to consumers. Plaintiff and  other consumers had their personal, private financial information impermissibly accessed  in the absence of any written request for services, and without consent. The impermissible  access of private and confidential information contained within a consumer’s credit report  violates the privacy rights conveyed by Congress in enacting the FCRA.    Defendant’s interference with a consumer’s legally protected interest in ensuring  his or her credit is not impermissibly accessed and used constitutes injury in fact for  purposes of Article III standing. Here, Defendants’ action resulted in a concrete and  particularized harm – a hard inquiry and an attendant score drop.     Accordingly, Defendant impermissibly invaded Plaintiff and other consumers’  legally protected interest in ensuring their credit reports are only accessed and used for  legally permissible purposes, proximately causing cognizable injury.   Plaintiff seeks certification of the following classes, initially defined as follows:  Class 1 – Impermissible Access. All natural persons residing in the United States  or its territories, excluding the Court and staff, whose consumer reports display an  inquiry by Defendant, and for which Defendant has no open account or record of a  written request for an account.   Class 2 – Impermissible Use. All natural persons residing in the United States or  its territories, excluding the Court and staff, whose consumer reports are recorded  as received by Defendant, and for which there is a record of a review of that data in  Defendant’s possession.    Excluded from the Classes is Defendant herein, and any person, firm, trust,  corporation, or other entity related to or affiliated with the Defendant, including, without  limitation, persons who are officers, directors, employees, associates or partners of  Defendant.    Numerosity    Upon information and belief, Defendant has made impermissible credit pulls, and  impermissibly used credit information of hundreds of consumers throughout the United  States, each of which violates the FCRA. The members of the classes, therefore, are  believed to be so numerous that joinder of all members is impracticable.    The exact number and identities of the class members are unknown at this time and  can only be ascertained through discovery. Identification of the class members is a matter  capable of ministerial determination from Defendant’s records.   Common Questions of Law and Fact    The Plaintiff's claims are typical of the claims of the class members.  Plaintiff and  all potential class members have claims arising out of the Defendant's common uniform  course of conduct complained of herein. Plaintiff's claims are typical of the claims of the  Class, and Plaintiff has no interests adverse or antagonistic to the interests of other  members of the Class.  Protecting the Interests of the Class Members    Plaintiff will fairly and adequately represent the class members' interests, in that  the Plaintiff's counsel is associated with experienced counsel and, further, anticipates no  impediments in the pursuit and maintenance of the class action as sought herein.     Neither the Plaintiff nor his counsel have any interests which might cause them not  to vigorously pursue the instant class action lawsuit.  Proceeding Via Class Action is Superior and Advisable    The members of the Class are generally unsophisticated individuals, whose rights  will not be vindicated in the absence of a class action.    Because Defendant has acted on grounds generally applicable to the proposed  classes, final injunctive and corresponding declaratory relief with respect to the classes as  a whole may be appropriate and as such, Plaintiff may seek certification under Fed. R.  Civ. P. 23(b)(2) or (b)(3). Without an injunction, Defendant’s violative business practices  are likely to continue.    Depending on the outcome of further investigation and discovery, Plaintiff may, at  the time of class certification motion, seek to certify one or more classes only as to  particular issues pursuant to Fed. R. Civ. P. 23(c)(4).    A class action will permit a large number of similarly situated persons to prosecute  their common claims in a single forum simultaneously, efficiently, and without the  duplication of effort and expense that numerous individual actions would engender. Class  treatment also will permit the adjudication of relatively small claims by many class  members who could not otherwise afford to seek legal redress for the wrongs complained  of herein.    Absent a class action, the class members will continue to suffer losses borne from  Defendant’s breaches of class members’ statutorily protected rights as well as monetary  damages, thus allowing and enabling: (a) Defendant's conduct to proceed and; (b)  Defendant to further enjoy the benefit of its ill-gotten gains.    Plaintiff repeats the allegations contained in the above paragraphs and incorporates  them as if specifically set forth at length herein.    Section 1681b of the FCRA limits access to consumer credit reports and requires  that specific requirements be met before a report is requested.     Defendant willfully violated 15 U.S.C. § 1681b(f) by obtaining consumer reports  without a permissible purpose.    Defendant maintained procedures and practices under which its agents, contractors  or employees obtained reports before the consumer signed up for telecom services, filled  out a credit application, or otherwise requested services.     Defendant maintained procedures and practices under which its agents, contractors  or employees misrepresented whether and under what circumstances Defendant would  access consumer reporting data.     Defendant represented to the credit reporting bureau(s) from which it obtained  consumer reports that it would request and use reports obtained from such bureau(s) only  for lawful purposes pursuant to 15 U.S.C. § 1681b.     Merely inquiring as to the availability of service in a certain area and simple rate  shopping does not invoke a business transaction initiated by the consumer, and thus,  Defendant did not have any of the permissible purposes set forth in 15 U.S.C. §  1681b(a)(3)(A-G) when it obtained Plaintiff’s and the proposed class members’ consumer  reports. There was no agreement to exchange goods or services for money as Plaintiff and  the proposed class members had not signed up for telecom services when Defendants  accessed their consumer reports.     Defendant violated 15 U.S.C. §§ 1681b, 1681n, and 1681q by obtaining Plaintiff’s  and the proposed class members’ consumer reports under false pretenses, without a  permissible purpose, and without consent. Defendant had no legitimate business need to  obtain these consumer reports since no business transactions had been initiated by these  consumers at the time that Defendant accessed those reports.     On or around July 18, 2016, Plaintiff contacted Cox by phone to learn about its  services and pricing.     After hearing about Cox’s offerings, Plaintiff chose not to proceed with the  services offered.    The Class   VIOLATIONS OF THE FAIR CREDIT REPORTING ACT  