19.  In or around February of 2012, Plaintiffs applied for work with  Defendant in Texarkana, Arkansas.   20.  Plaintiffs had to complete and sign various forms as part of the  employment application process. One of the forms was the "Background Investigation  Consent."   21.  On the "Background Investigation Consent," Plaintiffs had to agree to  "release Lindsey Management Co., Inc., the properties under its management and/or its  agents, and any person or entity, which provides information pursuant to this  authorization, from any and all liabilities, claims or law suits in regards to the  information obtained from any and all of the above reference sources used."   23.  Rather,  Defendant's  background  investigation  consent  contained  extraneous information which clearly violated the "stand-alone disclosure" requirement  and undercut the very purpose of the requirement.   24.  Despite its failure to provide Plaintiffs with the required stand-alone  disclosure, Defendant subsequently requested background checks from outside  consumer reporting agencies.   25.  Defendant willfully violated 15 U.S.C. § 1681b(b)(2)(A)(i) by procuring  consumer reports on Plaintiffs for employment purposes without first providing Plaintiffs  clear and conspicuous written disclosures, in a document consisting solely of the  disclosure, that a consumer report may be obtained for employment purposes.  v. ALLEGATIONS RELATING TO DEFENDANT'S BUSINESS PRACTICES   26.  Defendant conducts background checks on job applicants as part of its  standard employment application and screening process.   27.  Upon information and belief, a large number of Defendant's job applicants  are required to sign a Background Investigation Consent substantially identical to the  form attached hereto as Exhibit 1.   28.  Defendant does not perform these background checks in-house. Rather,  Defendant relies on outside consumer reporting agencies to obtain this information  and report it to Defendant.   29.  The background reports procured by Defendant constitute "consumer  reports" for purposes of the FCRA.   32.  Plaintiffs assert their claim on behalf of the class defined as follows:  Any person who applied to a Lindsey Management apartment  community and whose application included a liability release  regarding consumer reports and for whom Lindsey Management  procured a background check for employment purposes in the  period beginning five years prior to the filing of the Complaint and  continuing through the date the class list is prepared.   33.  The class is so numerous that joinder of all class members is  impracticable.   34.  Defendant regularly uses its disclosure to procure consumer reports on  job applicants.   35.  Hundreds of Defendant's current, former, and prospective employees  satisfy the class definition.   36.  Plaintiffs' claims are typical of the members of the class.  Defendant  typically uses an identical disclosure to procure consumer reports on prospective and  existing employees.   38.  Plaintiffs and their counsel will fairly and adequately protect the interests  of the class.   39.  Plaintiffs' counsel are competent to litigate Rule 23 class actions and  other complex litigation matters, and to the extent, if any, that they find that they are  not, they are able and willing to associate additional counsel.   40.  Plaintiffs are unaware of any existing litigation regarding the subject  matter of this lawsuit.   41.  Common questions of law and fact exist as to all members of the class  and predominate over any questions solely affecting individual members of the class,  including but not limited to:  a. Whether Defendant had a policy of procuring consumer reports on  prospective and existing employees;  b. Whether Defendant violated the FCRA by procuring such consumer  reports without a FCRA-compliant disclosure;  c. Whether Defendant's FCRA violations were willful;  d. The proper measure of statutory damages; and  e. The proper measure of punitive damages.   43.  Plaintiffs intend to send notice to all members of the class to the extent  required by Fed. R. Civ. P. 23. The names and addresses of the class members are  available from Defendant's records. 