85.  Plaintiff asserts his claims on behalf of the Rule 23(b)(3) “Damages Class”  defined as follows:  All individuals who only completed the portion of Defendant’s process  authorizing a credit pull that would not affect their credit scores, who did  not complete an application for a specific loan product, and on whom  Defendant made a hard credit inquiry in the two years predating the filing  of this Complaint and continuing through the date the class list is  prepared.   86.  Plaintiff asserts his claims on behalf of the Rule 23(b)(2) “Injunctive Relief  Class” defined as follows:  All individuals who only completed the portion of Defendant’s process  authorizing a credit pull that would not affect their credit scores, who did  not completion an application for a specific loan product, and on whom  Defendant made a hard credit inquiry in the four years predating the filing  of this Complaint and continuing through the date the class list is  prepared.   87.  Plaintiff also asserts his claims for injunctive relief on behalf of a Rule  23(b)(2) “Injunctive Relief Two-Year Subclass” defined as follows:  All individuals who only completed the portion of Defendant’s process  authorizing a credit pull that would not affect their credit scores, who did  not complete an application for a specific loan product, and on whom  Defendant made a hard credit inquiry in the two years predating the filing  of this Complaint and continuing through the date the class list is  prepared.   94.  Defendant represented to Plaintiff and the Damages Class that it would  perform a soft inquiry only into Plaintiff and the Damages Class members’ credit.   Defendant further represented that the inquiry it would do would not affect Damages Class  members’ credit scores.  These representations were false.   95.  Defendant violated the FCRA by knowingly and willfully procuring  information on Plaintiff and Damages Class members under false pretenses.  See 15 U.S.C.  § 1681q.   98.  Defendant represented to Plaintiff and the Damages Class that it would  perform a soft inquiry only into Plaintiff and the Damages Class members’ credit.     Obtaining Consumer Information Under False Pretenses  (On behalf of the Damages Class)   Obtaining Consumer Reports Without a Permissible Purpose  (On Behalf of the Damages Class)  