10.  Codified at 15 U.S.C. § 1681c(g), this provision states the following:  Except as otherwise provided in this subsection, no person that  accepts credit cards or debit cards for the transaction of business  shall print more than the last 5 digits of the card number or the  expiration date upon any receipt provided to the cardholder at the  point of sale or transaction.  15 U.S.C. § 1681c(g) (the “Receipt Provision”).   11.  After enactment, FACTA provided three (3) years in which to comply with its  requirements, mandating full compliance with its provisions no later than December 4, 2006.   13.  Card issuing organizations proceeded to require compliance with FACTA by  contract, in advance of FACTA’s mandatory compliance date. For example, the publication,  “Rules for Visa Merchants,” which is distributed to and binding upon all merchants that accept  Visa cards, expressly requires that “only the last four digits of an account number should be printed  on the customer’s copy of the receipt” and “the expiration date should not appear at all.”5   14.  Because a handful of large retailers did not comply with their contractual  obligations with the card companies and the straightforward requirements of FACTA, Congress  passed The Credit and Debit Card Receipt Clarification Act of 2007 in order to make technical  corrections to the definition of willful noncompliance with respect to violations involving the  printing of an expiration date on certain credit and debit card receipts before the date of the  enactment of this Act.6   15.  Importantly, the Clarification Act did not amend FACTA to allow publication of  the expiration date of the card number. Instead, it simply provided amnesty for certain past  violators up to June 3, 2008.   16.  In the interim, card processing companies continued to alert their merchant clients,  including Defendant, of FACTA’s requirements. According to a Visa Best Practice Alert in 2010:  Some countries already have laws mandating PAN truncation and the suppression  of expiration dates on cardholder receipts. For example, the United States Fair and  Accurate Credit Transactions Act (FACTA) of 2006 prohibits merchants from  printing more than the last five digits of the PAN or the card expiration date on any  cardholder receipt. (Please visit http://www.ftc.gov/os/statutes/fcrajump.shtm for  more information on the FACTA.) To reinforce its commitment to protecting  consumers, merchants, and the overall payment system, Visa is pursuing a global  security objective that will enable merchants to eliminate the storage of full PAN  5  Rules  for  Visa  Merchants,  33.   Defendant had actual knowledge of FACTA’s truncation requirement before it  began failing to comply with the requirement en masse.  Indeed, Karen Lopez, currently an Acting  Director at Defendant’s casino, claims to have conducted “internal investigations and department  trainings” specifically for the purpose of “protect[ing] the assets and every individual on property”  and “provide maximum deterrence, detection and immediate response to: theft, cheat/scams on  property, harm to our employees and guests . . .,” such as identity theft.22  So too, Stephan Yohay,  a current Surveillance Assistant Manager at Defendant’s casino.23 To that end, Lopez has also  received training on casino “data archiving” and casino “risk and needs assessment” through the  University of Reno, Extended Studies, Gaming Management Program, which training, upon  information and belief, would cover, among other things, the need for strict compliance with  35.  Moreover, there are numerous Florida statutes and operating regulations governing  gambling, pari-mutuel wagering, slot machines and card rooms -- all of which Savin and  Defendant’s other employees are well-versed in -- that require Defendant to maintain its  establishment in full compliance with state and federal regulations such as FACTA.     36.  Defendant’s self-professed knowledge and experience regarding federal laws  governing financial transactions no doubt translates to Defendant having intimate knowledge of  the requirements of FACTA, a federal law governing financial transactions.  Yet, Defendant has a  record of derelict data systems and regulatory noncompliance.  While CEO Scott Savin tellingly  admits that Defendant and its owners’ “only goal” is “to make money,” Dania Casino is one of the  worst performing casinos in the region.  Cost- and corner-cutting may help explain Defendant’s  record of reckless noncompliance and derelict processes and procedures.  For examples, just six  months after opening, Defendant was forced to close for a year, while “its owners were forced to  write a check to the state for nearly $400,000 after it under-reported its taxes for three months  because of an alleged software glitch.”25   37.  Most of Defendant’s business peers and competitors currently and diligently ensure  their credit card and debit card receipt printing process remains in compliance with FACTA by  consistently verifying their card machines and devices comply with the Receipt Provision.  Defendant could have readily done the same.   39.  As discussed above, the casino gaming industry is one of the main targets for  identity theft.  As such, companies operating in the sector should apply extra care in preserving  customers’ data and preventing identity theft. Given the size and years of experience of  Defendant’s business, and the various state and federal regulations governing its business, not to  mention the prevalence of financial crimes in and around its establishment, at minimum Defendant  was acting with reckless disregard of the FACTA requirements and purpose when printing eight  (8) digits of credit cards and debit cards, together with other pieces of sensitive information of its  customers, including their initialed signatures.   40.  Upon information and belief, the violations at issue arose when Defendant installed  new credit and debit card payment systems in its establishment.   41.  Upon information and belief, prior to the rollout of its new system, Defendant had  a written policy in place requiring the truncation of credit card account numbers; this is evidenced  by the fact that prior to the installation of the aforementioned system, Defendant was actually  truncating credit card and debit card account numbers in accordance with FACTA.   42.  Upon information and belief, a manual was provided to Defendant’s employees for  the operation of the new system which explained that the company is able to determine which  fields will appear on a printed receipt and further explained that the company is able to truncate  credit card and debit card numbers.   44.  On or about December 5, 2017, Plaintiff used his personal credit card to perform a  transaction at Defendant’s Casino at Dania Beach.    45.  Plaintiff paid using his personal credit card and subsequently was presented with  an electronically printed receipt bearing the first four (4) and last four (4) digits of his credit card  account number.   46.  In addition to bearing eight (8) digits of his credit card, the receipt identifies the  complete first and last name and initialed signature of Plaintiff, the individual to whom the card is  issued, as well as the card issuer (in this case VISA) and the transaction date and time.   47.  By printing of the first four (4) and last four (4) digits of his Visa credit card account  number Defendant breached Plaintiff’s confidence. Additionally, Defendant’s mishandling of his  information also breached an implied bailment.  E.  49.  Plaintiff falls within the class definition and is a member of the class. Excluded  from the class is Defendant and any entities in which Defendant has a controlling interest,  Defendant’s agents and employees, Plaintiff’s attorneys and their employees, the Judge to whom  this action is assigned and any member of the Judge’s staff and immediate family, and claims for  personal injury, wrongful death, and/or emotional distress.  A.  CERTIFICATION UNDER EITHER RULE 23(b)(2) OR (b)(3) IS PROPER.    50.  The members of the class are capable of being described without managerial or  administrative problems. The members of the class are readily ascertainable from the information  and records in the possession, custody or control of Defendant.   52.  Further, the first six (6) digits of a credit or debit card would readily determine  whether the corresponding card is a business or consumer card. That is because the first six (6)  digits of a credit or debit card number constitute what is known as the Bank Identification Number  (“BIN”) that represents several items of information, including whether it is a consumer card or  commercial (business) card. Finally, Visa, MasterCard, American Express and Discover only  allow specific BINs and BIN ranges to identify consumer cards, and specific BINs and BIN ranges  identify commercial (business) cards. Consumer cards and business cards do not share the same  BINs or BIN ranges.    53.  Plaintiff also proposes the following subclass, subject to modification by the Court  as required:  All persons in the United States who, within the two (2) years prior  to the filing of the complaint through the date of the Court’s order  granting class certification, (i) engaged in one or more transactions  using a consumer/individual-issued (viz. not business issued) debit  card or credit card at one or more of Defendant’s establishments  located non-tribal owned land in the United States, and (ii) for  which Defendant’s point-of-sale system was programmed to  generate a printed customer receipt displaying more than the last 5  digits of the credit or debit card number used in connection with  such transaction(s).   54.  While all Class Members have experienced actual harm as previously explained  herein, this suit seeks only statutory damages and injunctive relief on behalf of the class and it  expressly is not intended to request any recovery for personal injury and claims related thereto.  Plaintiff reserves the right to expand the class definition to seek recovery on behalf of additional  persons as warranted as facts are learned in further investigation and discovery.   54.  All or most purchases at Defendant's establishment for which a FACTA-violative  receipt is provided are paid with a consumer card, rather than a business card. To the extent this is  an issue, the payments made with the two types of cards are easily discernible: merchants are  charged different interchange fees for card transactions that vary based on whether the card is a  business card or a consumer card. There are different interchange categories and codes assigned  to each transaction that distinguish whether a card used for a transaction is a business card or a  consumer card. Defendant and its merchant bank(s) could easily identify whether a particular  transaction involved a business card or a consumer card.   55.  There is a well-defined community of interest in the questions of law and fact  involved affecting the parties to be represented. The questions of law and fact to the class  predominate over questions that may affect individual Class Members, including the following:  a.  Whether, within the two (2) years prior to the filing of this Complaint,  Defendant and/or its agents completed transactions by credit or debit card from  any consumer and subsequently gave that consumer a printed receipt upon  which more than the last five (5) digits of the card number was displayed;   b.  Whether Defendant’s conduct was knowing or reckless;  c.  Whether Defendant is liable for damages, and the extent of statutory damages  for each such violation; and  d.  Whether Defendant should be enjoined from engaging in such conduct in the  future.   55.  As a person that patronized Defendant’s establishment and received a printed  receipt containing more than the last five (5) digits of his credit card, Plaintiff is asserting claims  that are typical of the proposed class. Plaintiff will fairly and adequately represent and protect the  interests of the class in that Plaintiff has no interests antagonistic to any member of the class.   56.  Plaintiff and the members of the class have all suffered harm as a result of the  Defendant’s unlawful and wrongful conduct. Absent a class action, the class, along with countless  future patrons of Defendant’s establishment, will continue to face the potential for irreparable  harm. In addition, these violations of law would be allowed to proceed without remedy and  Defendant will continue such illegal conduct. Because of the size of the individual Class Members’  claims, few Class Members could afford to seek legal redress for the wrongs complained of herein.   57.  Defendant’s defenses are and will be typical of Plaintiff’s and the same or identical  for each of the members of the class and will be based on the same legal and factual theories. There  are no unique defenses to any of the Class Members’ claims.   58.  A class action is a superior method for the fair and efficient adjudication of this  controversy. Class-wide damages are essential to induce Defendant to comply with federal law.  The interest of Class Members in individually controlling the prosecution of separate claims  against Defendant is small. The maximum statutory damages in an individual action for a violation  of this statute are minimal. Management of these claims is likely to present significantly fewer  difficulties than those presented in many class claims.   59.  Defendant has acted on grounds generally applicable to the class, thereby making  appropriate final injunctive relief and corresponding declaratory relief with respect to the class as  a whole.  6.  Identity theft is a serious issue affecting both consumers and businesses. As of  2018, a Harris Poll revealed that nearly 60 million Americans have been affected by identity theft.2  There were a record high 16.7 million victims of identity fraud in 2017 alone, and account  takeovers (when a thief opens a credit card account or other financial account using a victim’s  name and other stolen information) tripled in 2017 from 2016, causing $5.1 billion in losses.3   61.  This section applies to any “device that electronically prints receipts” (hereafter  “Devices”) at point of sale or transaction. 15 U.S.C. §1681c(g)(3).   62.  Defendant employs the use of said Devices for transactions at its Casino at Dania  Beach establishment in Dania Beach, Florida.   63.  On or before the date on which this complaint was filed, Plaintiff and members of  the class were provided receipt(s) by Defendant that failed to comply with the Receipt Provision.   64.  At all times relevant to this action, Defendant was aware, or should have been  aware, of both the Receipt Provision as well as the need to comply with said provision.   65.  Notwithstanding the three-year period to comply with FACTA and its  accompanying provisions, nor the subsequent years since FACTA became effective; and having  knowledge of the Receipt Provision and FACTA as a whole; Defendant knowingly, willfully,  intentionally, and/or recklessly violated and continues to violate the FCRA and the Receipt  Provision.   68.  As a result of Defendant’s knowing or reckless violations of the FCRA, Plaintiff  and members of the class continue to be exposed to an elevated risk of identity theft. Defendant is  liable to Plaintiff and members of the class pursuant to 15 U.S.C. § 1681n for statutory damages,  punitive damages, attorney’s fees and costs.  *  *  *  WHEREFORE, Plaintiff Oneeb Rehman respectfully requests that this Court enter  judgment in his favor and the class, and against Defendant Dania Entertainment Center LLC, d/b/a  The Casino at Dania Beach, as follows:  a.   Granting certification of the Class;  b.   Awarding statutory damages;  c.   Awarding punitive damages;  d.   Awarding injunctive relief;  e.   Awarding attorneys’ fees, litigation expenses and costs of suit; and  f.   Awarding such other and further relief as the Court deems proper under the  circumstances.  7.  Congress enacted FACTA to prevent actual harm. See Pub. L. No. 108-159  (December 4, 2003) (“An Act . . . to prevent identity theft . . . and for other purposes.”)   9.  One such FACTA provision was specifically designed to thwart identity thieves’  ability to gain sensitive information regarding a consumer’s credit or bank account from a receipt  provided to the consumer during a point of sale transaction, which, through any number of ways,  could fall into the hands of someone other than the consumer.   A.  Background of FACTA   Plaintiff Oneeb Rehman (“Plaintiff”), on behalf of himself and other similarly situated  individuals, sues Defendant Dania Entertainment Center, LLC, d/b/a The Casino at Dania Beach  (“Casino” or “Defendant”), and alleges the following upon information and belief, and his own  personal knowledge.  number to protect persons from identity theft.   B.  CASINOS SUCH AS DEFENDANT’S ESTABLISHMENT ARE BREEDING 