Consumer complaint received 2025-04-20 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Improper use of your report — Reporting company used your report improperly
Company: LEXISNEXIS
State: NY

Complaint narrative:
XXXX XXXX XXXX XXXX XXXX XXXX, NY XXXX XXXX ( XXXX ) XXXX Date : XX/XX/XXXX Re : CFPB Complaint No. XXXX Rebuttal to LexisNexis XXXX XXXX XXXX XXXX Response To Whom It May Concern, This is a formal rebuttal to the deceptive and legally insufficient response submitted by LexisNexis XXXX XXXX XXXXXXXX regarding the above-referenced complaint. LexisNexis has intentionally mischaracterized its role and ignored direct demands for corrective action, continuing to evade responsibility for its ongoing violations of federal and state consumer protection laws.

1. LexisNexis is a Consumer Reporting Agency and Subject to FCRA LexisNexis claims it is not a consumer reporting agency, yet its business model clearly falls within the definition set forth under the Fair Credit Reporting Act ( 15 U.S.C. 1681a ( f ) ), which includes any entity that assembles or evaluates consumer information for the purpose of furnishing consumer reports to third parties.

This has been confirmed by the U.S. Supreme Court in TransUnion XXXX XXXX XXXX, XXXX XXXX XXXX XXXX ( XXXX ), where the Court held that companies that compile, maintain, and distribute consumer information that may be used in decision-makingsuch as for credit, employment, or insuranceare subject to the FCRA. LexisNexis actively sells XXXX, Accurint, and other reports that affect consumer decisions, meeting this threshold. 

Furthermore, in Doe v. LexisNexis XXXX & XXXX. XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX. XXXX ), the court allowed claims under the FCRA to proceed against LexisNexis for failing to ensure accuracy and proper notice to consumers. This precedent directly rebuts LexisNexis false claim of exemption. 

2. File Suppression is Not Equivalent to Deletion LexisNexis admits it has merely " suppressed '' my file. However, this does not satisfy my demand for permanent deletion of my personal and financial data from all internal and external databases. Suppression does not prevent LexisNexis from continuing to use, analyze, or sell my data behind the scenes. This practice is deceptive and continues to expose me to unauthorized data use, profiling, and privacy risks. 

3. Ongoing Violation of Federal and State Privacy Laws LexisNexis continues to willfully violate the following laws : FCRA ( 15 U.S.C. 1681b ) by furnishing consumer information to third parties without a legally defined permissible purpose or my written consent. 

XXXX XXXX ( 15 U.S.C. 68016827 ) by failing to safeguard and limit the dissemination of sensitive financial information. 

XXXX XXXX XXXXXXXX XXXX ( XXXX XXXX. XXXXXXXX XXXX XXXXXXXX ) by maintaining personal data without proper security measures, transparency, or consent for sale or profiling. 

The claim that LexisNexis can not verify my identity is meritless, considering they have already mailed me correspondence using my verified name and address, and have actively sold my data to credit bureaus and third parties who rely on their files. This is a transparent stall tactic and a textbook case of unclean hands. 

4. Demand for Immediate Corrective Action I hereby demand that LexisNexis : Permanently delete all personal, financial, and identifying information associated with me from its databases and affiliated entities.

Cease all current and future sales, transfers, or disclosures of my personal data.

Acknowledge violations under FCRA and GLBA and provide a written compliance plan.

Provide written confirmation that these actions have been taken within 15 days.

5. Regulatory and Legal Escalation if No Acti
on Taken If LexisNexis fails to comply within 15 days, I will : File additional complaints with the Federal Trade Commission ( FTC ), the New York State Attorney General, and other regulatory agencies.

Pursue civil litigation for financial harm, privacy violations, and data misuse.

Publicly disclose LexisNexis misconduct to relevant media and consumer advocacy platforms. 

Your attempt to mislead the CFPB and evade lawful obligations is unacceptable and will not go unchallenged. 

Sincerely, XXXX XXXX XXXX XXXX

Company response to consumer: Closed with explanation