13.  When selling automobiles, Fred Beans holds itself out in retail installment sales  contracts with consumers as a creditor-seller to whom consumers are obligated to pay the amount  financed, prior to immediately transferring financing to a third-party financier/creditor.   15.  On March 20, 2017, Mr. Brogan entered into a Retail Installment Sales Contract  with Fred Beans ("RISC #1") and purchased a 2016 Subaru Impreza (the "Vehicle"). RISCS #1  is attached as Exhibit 1.   16.  RISC #1 included, among other things, a Federal Truth-In-Lending disclosure  regarding the financing terms offered by Fred Beans for the sale of the Vehicle:  49.  Plaintiff asserts his claim in Count One and Count Two on behalf of the "False  Finance Charge Class" defined as follows:  False Finance Charge Class:  All consumers who purchased  vehicles from Fred Beans in the United States that: (1) where the  retail installment sales contract falsely stated the Finance Charge;  (2) were Pennsylvania residents at the time of the purchase; (3)  within the three years prior to the filing of the Complaint until the  date of final judgment in the action.   50.  Plaintiff asserts his claim in Counts One and Two on behalf of the "Multiple RISC  Class" (illusory financing class) defined as follows:  Multiple RISC Class: All consumers who purchased vehicles from  Fred Beans in the United States that: (1) entered into a retail sales  installment contract with Fred Beans; (2) who were presented with  more than one retail sales installment contract without a written  cancellation of the prior retail installment sales contract; (3) were  Pennsylvania residents at the time of the purchase; (4) within the  five years prior to the filing of the Complaint until the date of final  judgment in the action.   52.  Plaintiff asserts his claim in Count Three on behalf of the "Unauthorized Inquiry  Class" defined as follows:  Unauthorized Inquiry Class: All consumers who entered into  retail sales installment contracts with Fred Beans in the United  States: (1) where Fred Beans continued to conduct hard credit  inquiries following the execution of the retail sales installment  contract; (2) within five years prior to the filing of the Complaint  until the date of final judgment in the action.·   53.  Numerosity. The Putative Classes are so numerous that joinder of all Class  members is impracticable.  Fred Beans regularly improperly issues retail sales installment  contracts with false finance charges; regularly issues multiple retail sales installment contracts  without any written cancellation of the prior retail sales installment contracts with consumers with  changed finance terms; regularly charges document fee/dealer fees as part of its retail sales  installment contracts that it regularly issues, that bears no rational relationship to the preparation  and completion of documents; and continues to conduct hard credit inquiries by obtaining credit  reports without any permissible purpose in violation ofTILA, the FCRA and PAUFA.   55.  Adequacy. Plaintiff is an adequate representative of the Putative Classes. As a  person who was issued retail sales installment contracts with false finance charges; issued multiple  retail sales installment contracts without any written cancellation of the prior retail sales  installment contracts with consumers with changed finance terms; was charged document  fee/dealer fee as part of Fred Beans retail sales installment contracts that it regularly issues, that  bears no rational relationship to the preparation and completion of documents; and was subject to  hard credit inquiries by Fred Beans without a permissible purpose all in violation of TILA, the  FCRA and PA UFA, Plaintiffs interests are aligned with, and are not antagonistic to the interests  of the members of the Putative Classes. Plaintiff has retained counsel competent and experienced  in complex class action litigation.   57.  This case is maintainable as a class action under Fed. R. Civ. P. 23(b)(l) because  prosecution of actions by or against individual members of the Putative Classes would result in  inconsistent or varying adjudications and create the risk of incompatible standards of conduct for  Defendant. Further, adjudication of each individual Class member's claim as a separate action  would potentially be dispositive of the interest of other individuals not a party to such action,  impeding their ability to protect their interests.   58.  This case is maintainable as a class action under Fed. R. Civ. P. 23(b)(2) because  Fred Beans has acted or refused to act on grounds that apply generally to the Putative Class, so  that final injunctive relief or corresponding declaratory relief is appropriate respecting the Classes  as a whole.   60.  Plaintiff intends to provide notice to all members of the Putative Classes to the  extent required by Rule 23. The name and addresses of the Putative Class members are available  from Defendant's records.  61.  Plaintiff incorporates by reference all other allegations and paragraphs of the  Complaint as if set forth herein at length.   62.  The transaction described herein was a consumer credit transaction with the  meaning of the Truth in Lending Act, 15 U.S.C. §§ 1601 et seq.   63.  Fred Beans is a "Creditor" pursuant to TILA U.S.C. § 1602(£).   64.  As a creditor, Fred Beans regularly extends consumer credit that is subject to a  finance charge or payable in more than four installments and is the person to whom the transaction  which is the subject of this action is initially payable, 15 U.S.C. § 1602(g) and Reg. Z §  226.2(a)(l 7). Defendant is also identified as the seller-creditor on the retail sales installment  contracts at issue.   66.  Pursuant to 15 U.S.C. § 1638, the creditor must disclose material terms such as the  true finance charge, amount financed and APR.   67.  The Federal Truth in Lending Disclosures in the retail sales installment contracts  were false and misleading as, among other reasons, the dealership repeatedly miscalculated the  financing terms in its favor in order to generate further revenue from automobile sales.   68.  Moreover, Defendant had no intention to honor the financing terms contained in its  retail sales installment contracts, which would always be subject to Defendant's unilateral  determination.   69.  Plaintiff and the Putative classes are entitled to damages in the amount that the court  may allow, along with attorneys' fees and expenses pursuant to 15 U.S.C. § 1640(a)(2)(A)(i) and  15 U.S.C. 1640(a)(3).  70.  Plaintiff incorporates by reference all other allegations and paragraphs of the  Complaint as if set forth herein at length.   71.  The PAUFA, 73 P.S. §201-1 provides a private right of action for any consumer  who "suffers any ascertainable loss of money or property" as a result of an unlawful method, act  or practice. 73 P.S. § 201-9.2(a).   72.  P AUF A makes it unlawful for a person to engage in unlawful business practices,  including, but not limited to any "fraudulent or deceptive conduct which creates a likelihood of  confusion or of misunderstanding." 73 P.S. §201-2(4)(xvii).   74.  Defendant further violated PAUF A by, among other reasons, charging consumers  in its retail sales installment agreements dealer fees that were purportedly for services rendered in  preparing documentation for automobile sales. The dealer fees, however, bear no relationship to  costs associated with document preparation, but are actually a hidden expense to consumers so the  Defendant can generate further revenue from automobile sales.  7 5.  Defendant further violates PA UFA by, among other reasons, presenting consumers  with numerous retail sales installment contracts for Defendants own benefit, even though the  contracts are final binding agreements, for Defendant's own benefit so that consumers are bound  by the agreement while the Defendant is not.   76.  Plaintiff and the Putative Class are entitled to three times statutory damages,  including attorneys' fees and costs.  77.  Plaintiff incorporates by reference all other allegations and paragraphs of the  Complaint as if set forth herein at length.   78.  Plaintiff is a "consumer" as defined by the FCRA.   79.  Fred Beans is a "person" as defined by the FCRA.   80.  Fred Beans used a "consumer report," as defined by the FCRA.   81.  Defendant violated Sections 168ln and 16810 of the Fair Credit Reporting Act by  willfully and negligently causing unauthorized and excessive credit inquiries to be made of  Plaintiff and the Class.   83.  The conduct of Defendant was a direct and proximate cause, as well as a substantial  factor in bringing about the harm to the Plaintiff and Class that are outlined more fully above and,  as a result, Defendant is liable to Plaintiff and the Class for the full amount of statutory damages,  punitive damages, attorney's fees and costs of litigation, as well as such further relief, as may be  permitted by law.   84.  The foregoing violations were willful. Fred Beans knew that it was required to  obtain Plaintiffs consent prior to submitting subsequent credit inquiries after it agreed to provide  financing. Fred Beans acted in deliberate or reckless disregard of its obligations and the rights of  Plaintiff and other Class members under 15 U.S.C. § 1681b(b)(2)(A)(i).   85.  Plaintiff and the Putative Class are entitled to statutory damages of not less than  $100 and not more than $1,000 for each and every one of these violations, pursuant to 15 U.S.C.  § 1681n(a)(l)(A).   86.  Plaintiff and the Putative Class are also entitled to punitive damages for these  violations, pursuant to 15 U.S.C. § 168ln(a)(2).   87.  Plaintiff and the Putative Class are further entitled to recover their costs and  attorneys' fees, pursuant to 15 U.S.C. § 1681n(a)(3).  VIOLATIONS OF TRUTH IN LENDING ACT   VIOLATIONS OF THE FAIR CREDIT REPORTING ACT   VIOLATIONS OF THE PENNSYLVANIA UNFAIR TRADE PRACTICES AND  CONSUMER PROTECTION LAW  