10.  Experian has used a series of different vendors over the years.  Originally, these vendors relied on in-person manual reviews of courthouse records to  collect tax lien information. Typically, clerk’s offices would make available copies of  termination records—releases and withdrawals. Weekly update reports were made  available. Docket books were examined. A careful, in-person review was conducted.   11.  However, Experian and its vendors stopped this more careful process  and began collection of tax lien information solely from automated resources.    12.  After the switch to this automated process, Experian and its vendors  rarely collected any tax lien release or withdrawal information. And the only “in- person” review of the automated data was attempted only after a consumer made a  formal dispute, and even then, only rarely.    14.  Upon information and belief, the methods and processes used by  Experian and its vendor to gather tax lien releases and withdrawals was materially the  same throughout the class period.   15.  At all times relevant to this Complaint, Experian’s conduct regarding the  collection of tax lien release or withdrawal information was willful and carried out in  reckless disregard for a consumer’s rights under the FCRA. For example, Experian’s  conduct was willful because it was intentionally accomplished through Experian’s  intended procedures and because Experian believed that its diligence in collecting  and reporting derogatory information was of greater economic value to its paying  customers than the collection of “disposition” information that demonstrated that the  debt was no longer owed.     16.  Experian has also been on notice of these issues throughout the  pendency of Soutter v. Equifax Information Services, LLC, 3:10-cv-107 (E.D. Va.).  Experian has also been sued for similar conduct in other jurisdictions. Pumphrey v.  Experian Info. Solutions, Inc., 3:11-cv-574 (E.D. Va.); Clark v. Experian Info.  Solutions, Inc., 3:16-cv-32 (E.D. Va.); Brown v. Experian Info. Solutions, Inc., 3:16- cv-670 (E.D. Va.).    18. As a result of Experian’s conduct, Plaintiff and the putative class members  suffered particularized and concrete injuries, including damages to their reputations,  reductions to their credit scores, and increased risks that they would be denied credit.   Facts as to Plaintiff Bridgette Fuller   19.  On or around September 18, 2006, the Delaware Division of Revenue  filed a tax lien against Ms. Fuller in New Castle Superior Court in New Castle,  Delaware.   20.   Ms. Fuller’s lien was thereafter satisfied and the Delaware Division of  Revenue filed a Notice of Satisfaction in New Castle Superior Court on or around  June 18, 2007.   21.  Notwithstanding that this Notice was filed on or around June 18, 2007,  Experian nonetheless failed to accurately report the fact that the lien had been  satisfied on one or more consumer reports provided to Ms. Fuller and other third  parties after that date.   22.  Within the past two years, Experian published Ms. Fuller’s consumer  report on at least nine different occasions to multiple third parties.   24.  Plaintiff brings this action individually and as a class action, pursuant to  Rule 23 of the Federal Rules of Civil Procedure, on behalf of the following class:  All natural persons who meet every one of the following definitional  requirements:  a.   the Pennsylvania, New Jersey, Delaware, or Virgin Islands court  records show that the person was the subject of a federal or state  tax lien filing;  b.  the court records also show that a release or withdrawal of that tax  lien was subsequently filed;  c.  Experian’s records note that a consumer report regarding the  person was published 15 days for more following the date of the  lien release or withdrawal filing, but within two years preceding  the filing date of this Complaint; and  d.  the Experian report contained a record of the tax lien, but did not  also reflect that the tax lien had been released or withdrawn.   Subclass 1:   The individuals described above who were the subject of  only one or more tax liens that were each withdrawn and  who had no other tax liens in their file;  Subclass 2:   All individuals who meet the general class definition  criteria, but do not meet the requirements of Subclass 1.   26.  Existence and Predominance of Common Questions of Law and Fact.  Fed. R. Civ. P. 23(a)(2). Common questions of law and fact exist as to all class  members. These questions predominate over the questions affecting only individual  members. These common legal and factual questions include, but are not limited to:  a.  Whether Experian adopted procedures that collected and reported  updates to federal and state tax liens that were less systematic and  effective than those it used to collect and report the underlying tax liens;  b.  Whether Experian’s uniform procedure (including those of its agent) for  collecting tax lien releases and withdrawals was a reasonable procedure  to ensure maximum possible accuracy in the consumer reports it  furnished;  c.  Whether Experian did so recklessly, knowingly, or intentionally in  conscious disregard of the class members’ rights; and  d.  Whether Experian’s conduct violated the FCRA.   28.  Adequacy. Fed. R. Civ. P. 23(a)(4). Plaintiff is an adequate  representative of the class because her interests coincide with, and are not  antagonistic to, the interests of the class members she seeks to represent; she has  retained counsel competent and experienced in such litigation; and she will  vigorously prosecute this action. Plaintiff and her counsel will fairly and adequately  protect the class members’ interests.   30.  Experian violated 15 U.S.C. § 1681e(b) as to the Plaintiff and to the  class by failing to establish or to follow reasonable procedures to assure maximum  possible accuracy in the preparation of the consumer reports it furnished regarding  the Plaintiff and other class members.   31.  The Plaintiff and each putative class member suffered an actual injury  and loss because of Experian’s violation of 15 U.S.C. § 1681e(b).    32.  For example, the rights at issue were determined by Congress to be  important measures of Experian’s process to ensure continued accuracy and  completeness in its files and reports.   33.  In each instance for the Plaintiff and each class member, their actual  credit reports were materially inaccurate and reported a major derogatory public  record that Experian was legally obligated to correct or omit.   34.  Experian’s violation of 15 U.S.C. § 1681e(b) was willful, rendering it  liable under 15 U.S.C. § 1681n.   35.  In the alternative, Experian’s violation of 15 U.S.C. § 1681e(b) was  negligent, rendering it liable under 15 U.S.C. § 1681o.   8.  Experian provided reports about the Plaintiff and each putative class  member which contained inaccurate tax lien information.   Violation of 15 U.S.C. § 1681e(b)  