Consumer complaint received 2025-05-14 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account status incorrect
Company: Experian Information Solutions Inc.
State: TX

Complaint narrative:
XXXX XXXX Wednesday XXXX XXXX, XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, TX XXXX XXXX : XX/XX/XXXX SSN ( Last XXXX Digits ) : XXXX XX/XX/XXXX To : XXXX XXXX XXXX XXXX XXXX 
XXXX XXXX XXXX, # XXXX XXXX, NY XXXX CC : Consumer Financial Protection Bureau XXXX XXXX XXXX XXXXXXXX XXXX DC XXXX Texas XXXX XXXX XXXX Attorney General XXXX XXXX XXXX XXXX. XXXX XXXX XXXX, TX XXXXXXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX  XXXX DC XXXX XXXX NOTICE OF FRAUD DISPUTE, DEMAND FOR VALIDATION, CEASE AND DESIST, AND INTENT TO FILE SUIT RE : XXXX XXXX  Account # XXXX / Alleged XXXX XXXX Account # XXXX NOTICE TO AGENT IS NOTICE TO PRINCIPAL. NOTICE TO PRINCIPAL IS NOTICE TO AGENT. 
To Whom It May Concern, This is your FINAL WARNING to cease and desist all collection efforts, credit reporting, and communication regarding the fraudulent account referenced above ( XXXX XXXX # XXXX, XXXX XXXX # XXXX ). Your response dated XX/XX/XXXX ( Reference : XXXX ), is a brazen attempt to shirk accountability, filled with baseless excuses and flagrant violations of the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 et seq., the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., the Uniform Commercial Code ( UCC ), and Texas consumer protection laws. Your refusal to provide the purchase agreement, reliance on a fraudulent claim that the now-defunct XXXX XXXX notified me via an email address used solely for wedding purposes, and continued reporting of this disputed debt are predatory and unlawful. I am fully prepared to pursue relentless litigation to hold XXXX XXXX XXXX XXXX accountable for every violation. 
Page XXXX of XXXX XXXX XXXX Wednesday XXXX XXXX, XXXX I unequivocally deny any liability for this debt. I have never entered into any agreement with XXXX XXXX, which is no longer in business, or Bounce AI, nor have I authorized any contract, application, or transaction related to this account. The email address you cite, XXXX, was used exclusively for wedding-related matters and never for financial transactions, proving this account is the result of identity theft, as documented in my FTC Identity Theft Report ( # XXXX, dated XX/XX/XXXX ). All rights are expressly reserved, and I do not waive any legal protections by sending this letter. 
XXXX. IDENTITY THEFT MANDATORY REMOVAL REQUIRED As a victim of identity theft, I have provided you with my FTC Identity Theft Report ( # XXXX ) and filed complaints with the CFPB ( Complaint XXXX : XXXX, XXXX, XXXX XXXX, XXXX ). Under FCRA 605B, you are legally obligated to block all tradelines associated with this fraudulent account from my credit reports within XXXX business days of receiving my identity theft report. XXXX XXXX closure further supports my claim, as defunct companies are more susceptible to data breaches and fraudulent account creation. Your failure to cease reporting since my initial notification on XX/XX/XXXX is a willful violation of FCRA 623 ( a ) ( 6 ), which prohibits furnishing information identified as resulting from identity theft without verification. Your continued reporting, as confirmed by Experian ( 11/25/2024, 1/9/2025 ), also violates FCRA 1681s-2 ( a ) ( 1 ) ( A ) by furnishing inaccurate information and 1681s-2 ( a ) ( 3 ) by failing to mark the account as disputed.

You are ORDERED to : Remove this account from Experian, Equifax, and TransUnion within XXXX business days ; Notify each CRA in writing of the deletion, citing my identity theft claim and Tallys closure ; Provide me with written confirmation of compliance. 
Noncompliance will trigger statutory damages of {$1000.00} per violation, plus actual and punitive damages, under FCRA 1681n.

2. DEMAND FOR COMPLETE, LEGALLY SUFFICIENT VALIDATION FDCPA 1692g ( b ) Your XX/XX/XXXX response is a deplorable attempt to evade your obligations under FDCPA 1692g ( b ). Your claim that XXXX XXXX, a company no longer in operation, sent an email to XXXX on XX/XX/XXXX, is baseless and fraudulent. That email address was used solely for wedding-related matters and never for financial transactions, as Ive consistently stated in my CFPB complaints and identity theft report. Your failure to XXXX XXXX of XXXX XXXX XXXX Wednesday XXXX XXXX, XXXX provide verifiable proof of this alleged notification ( e.g., email headers, SMTP logs, delivery receipts ) renders your claim inadmissible and bolsters my assertion that this account is fraudulent. 
XXXX closure further undermines your reliance on their alleged notice, as you can not verify its authenticity or delivery with a defunct entity. Moreover, Tallys notification, even if true, does not absolve your duty as the debt collector to validate the debt directly with me, per FDCPA XXXX ( b ) and XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ). 
Your refusal to provide the purchase agreement between XXXX XXXX and Bounce AI, citing it as a confidential business record, is a blatant violation of FDCPA 1692g ( b ). Courts have unequivocally held that validation requires proof of assignment, including purchase agreements, to establish the XXXX legal right to collect ( see XXXX v. XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) ; XXXX XXXX XXXX, XXXX, XXXX & XXXX, XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) ). Your confidentiality excuse is legally void, as FDCPA takes precedence, and you may redact sensitive terms if necessary. XXXX closure heightens your obligation to produce this agreement, as it is the only way to verify the debts transfer. Your assertion that providing a line of credit agreement and monthly statements is sufficient is patently false, as these do not prove your ownership or my liability, especially given my identity theft claim and the misuse of the wedding email address. 
You are ORDERED to produce, within XXXX calendar days : XXXX. The original wet-ink signed contract or cryptographically authenticated digital signature with XXXX XXXX, allegedly executed on XX/XX/XXXX, bearing my verifiable consent ; XXXX. A complete, notarized chain of title, including the purchase agreement between XXXX XXXX and Bounce AI ( dated XX/XX/XXXX ) and any intermediary assignments, per FDCPA 1692g ( b ) and UCC 9-210 ; 3. A full accounting ledger detailing all charges, fees, payments, interest calculations, and adjustments from XX/XX/XXXX to present ; XXXX. All communications, emails, billing statements, notices of default, and payment records, including the alleged XXXX notification email of XX/XX/XXXX to XXXX ; XXXX. Verifiable proof of delivery ( with metadata, timestamps, and recipient confirmation ) for all notices you claim were sent, including your XX/XX/XXXX email, XX/XX/XXXX text, physical mail to XXXX XXXX XXXX XXXX, and XXXX alleged XX/XX/XXXX email. 
Failure to provide every item in full will be deemed a willful violation of FDCPA 1692g ( b ), subjecting you to damages under 1692k. Partial compliance will not be tolerated. 
Page XXXX of XXXX XXXX XXXX Wednesday XXXX XXXX, XXXX XXXX. CEASE AND DESIST ORDER FDCPA XXXX ( c ), XXXXXXXX XXXX XXXX XXXXXXXX Effective immediately, I invoke my rights under FDCPA XXXX ( c ) and XXXX XXXX XXXX XXXX to ORDER you to cease all communication with me, including but not limited to phone calls ( XXXX, XXXX ), emails ( XXXX, XXXX ), texts, or mail. You are permitted to contact me only to : Provide the complete validation demanded above ; Confirm in writing that the account has been deleted, canceled, and removed from all CRAs. 
Any other contact will be treated as harassment under FDCPA 1692d and Texas Deceptive Trade Practices Act ( DTPA ) 17.46 ( b ) ( 24 ), and documented for litigation. I expressly prohibit contact at XXXX, XXXX, or any other personal channels. 
XXXX. NO STANDING CHALLENGE TO TITLE AND ASSIGNMENT Your refusal to provide the purchase agreement, especially with XXXX XXXX no longer in business, violates : UCC 9-210 & 9-404 : Debtors may demand proof of assignment ; FDCPA 1692g ( b ) : Collectors must prove legal ownership ; Gearing v. Check Brokerage XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX. XXXX ) : Validation requires evidence of assignment ; Clark v. Capital Credit & Collection Services , Inc., XXXX XXXX XXXX ( XXXX XXXX. XXXX ) : Mere assertions of debt are insufficient. 
XXXX closure casts significant doubt on the legitimacy of the debts transfer, and without the purchase agreement, you lack standing to collect or report this debt, rendering your actions ultra vires and exposing you to liability for tortious interference and FDCPA 1692e ( 2 ) ( A ).

5. UNLAWFUL CREDIT REPORTING IMMEDIATE DELETION DEMANDED Your continued reporting of this fraudulent, unvalidated debt to Experian, Equifax, and TransUnion, as admitted in your XX/XX/XXXX response, violates FCRA 605B, 623 ( a ) ( 6 ), and 1681s-2 ( a ) ( XXXX ) ( A ). You have no permissible purpose to report a debt Ive identified as fraudulent, XXXX XXXX of XXXX XXXX XXXX Wednesday XXXX XXXX, XXXX and your failure to mark it as disputed violates 1681s-2 ( a ) ( 3 ). Your claim that I havent demonstrated inaccuracies is baseless, as my FTC Identity Theft Report, CFPB complaints, and XXXX XXXX provide conclusive evidence of fraud. You are ORDERED to : Delete the account from all CRAs within XXXX days ; Send written confirmation of deletion to each CRA and to me ; Cease all furnishing of this information immediately. 
Continued reporting will be treated as malicious noncompliance, triggering damages under FCRA 1681n, 1681o, and Tex. Bus. & Com. Code 20.01 et seq.

XXXX. PRESERVATION OF EVIDENCE LITIGATION HOLD You are ORDERED to preserve all records related to this account, including : Emails, including the alleged Tally notification of XX/XX/XXXX to XXXX ; Call logs, recordings, and text messages ; Purchase agreements, bills of sale, and assignment records ; Internal notes, compliance logs, and validation attempts. 
Any destruction, alteration, or spoliation of evidence will be reported to the court as bad faith, warranting sanctions and adverse inferences. 
XXXX. FINAL WARNING INTENT TO SUE This is your LAST CHANCE to comply. If every demand in this letter is not met within 10 days, I will file a lawsuit in the XXXX XXXX XXXX for XXXX XXXX XXXX XXXX Texas, asserting : FDCPA violations ( 15 U.S.C. 1692 et seq. ), including failure to validate, false representations, and harassment ; FCRA violations ( 15 U.S.C. 1681 et seq. ), including furnishing inaccurate data and ignoring identity theft ; UCC Article 9 violations for lack of standing ; XXXX XXXX XXXX XXXX violations for unlawful collection practices ; Texas XXXX violations ( XXXX ( b ) ) for deceptive practices ; Common law claims : defamation, negligence, intentional infliction of emotional distress, and tortious interference. 
Page XXXX of XXXX XXXX XXXX Wednesday XXXX XXXX, XXXX I will seek : {$1000.00} statutory damages per FDCPA violation ( 15 U.S.C. 1692k ) ; {$1000.00} per FCRA violation, plus actual and punitive damages ( 15 U.S.C. 1681n ) ; Treble damages under Texas XXXX ; Injunctive relief to halt collection and reporting ; Attorney fees and costs. 
Your predatory tactics, including prior failures to include the mini-Miranda ( XXXX communications ), reliance on a defunct creditor, and continued reporting despite my identity theft claim, have caused me significant distress, damaged my credit, and wasted my time. I will pursue all remedies to the fullest extent of the law, including subpoenaing the purchase agreement and exposing your non-compliance in court. Govern yourselves accordingly. 
Sincerely, XXXX XXXX Enclosures : FTC Identity Theft Report ( # XXXX, XX/XX/XXXX ) Copies of CFPB Complaints ( XXXX : XXXX, XXXX, XXXX, XXXX ) Experian Dispute Results ( XX/XX/XXXX, XX/XX/XXXX ) XXXX XXXX Response ( XX/XX/XXXX, Reference : XXXX )

Company response to consumer: Closed with explanation