1.   whether Defendant National Recall & Data Services Inc. and Defendant Charles  Holley obtained, re-disclosed, and/or resold Plaintiffs and Class Member's personal  information contained within motor vehicle records maintained by the State motor  vehicle departments;    2.   whether Defendant Naviss obtained, re-disclosed, and/or resold Plaintiffs and Class  Member's personal information contained within motor vehicle records  maintained by the State motor vehicle departments;    3.   whether Defendant National Recall & Data Services Inc. and Defendant Charles  Holley had a DPPA permissible use to obtain, re-disclose, and/or resell Plaintiffs  and Class Member's personal information contained within motor vehicle records  maintained by the State motor vehicle departments;    4.   whether Defendant Naviss had a DPPA permissible use to obtain, re-disclose,  and/or resell Plaintiffs and Class Member's personal information contained within  motor vehicle records maintained by the State motor vehicle departments;   5.  whether Defendant National Recall & Data Services Inc. and Defendant Charles  Holley obtained the written express consent of Plaintiffs and Class Members to  obtain, re-disclose, and/or resell Plaintiffs and Class Member's personal  information contained within motor vehicle records maintained by the State motor  vehicle departments;   58. Proof of such DPPA violations by the Defendants, the basis of their class action,  evidencing a pattern across the United States, was the result of a covert investigation  conducted by the State of Texas Department of Motor Vehicle Department which  “seeded” motor vehicle records sold to “Bulk Requestors”, referencing persons and/or  entities that obtain the entire database of state motor vehicle records and/or obtain  all periodic updates. “Emma Lusk, 2213 Buffalo Gap, Leander Tx. 78641-888” was  seeded data provided by the State of Texas Department of Motor Vehicle Department  to Defendant National Recall & Data Services Inc. and Defendant Charles Holley, which  was then re-disclosed and/or re-sold to Defendant Naviss and National Affiliates, and  used for direct marketing, a violation of the DPPA.    6.   whether Defendant Naviss obtained the written express consent of Plaintiffs and  Class Members to obtain, re-disclose, and/or resell Plaintiffs and Class Member's  personal information contained within motor vehicle records maintained by the  State motor vehicle departments;   60. The unauthorized access to State Motor Vehicle Records exists at the “cost” of the  Plaintiffs and Class Member’s privacy and security, creating a reasonable fear of  present and future injury, compelling individuals to take costly and burdensome  measures to protect their privileged information from risk of access and probable  harm. Kristi Dyroff, an advocate with the National Organization for Victim Assistance,  discussed the consequences from the improper access to motor vehicle records:   Kristy Dyroff, National Organization for Victim Assistance, “DPPA fails to provide  protection for crime victims”, October 30, 2013, (last accessed June 3, 2016), online:  http://www.trynova.org/category/nove-blog.  B. Defendants’ Business Practices and Associations   62. There are at least six (6) principal participants in a VSC Industry: (1) the consumer who  purchases the VSC (the “Consumer”), (2) the dealer that markets the VSC to the          consumer (the “Dealer”), (3) the administrator that develops and administers the VSC  itself and is the party obligated to reimburse the cost of covered repairs (the  “Administrator”), (4) the risk retention group that guarantees to pay covered claims if  the Administrator does not satisfy its obligation to the Consumer (the “Insurer”), (5)  the financing organization that enables the Consumer to pay for the VSC (the  “Financing Organization”), and (6) “the supplier,” referencing individuals and entities  that supply the leads originating from sources that include obtaining state motor  vehicle records.    64.  Defendant National Recall & Data Services Inc.  is a corporation involved in the Direct  Marketing Industry, acting as a Direct Market Provider assisting Direct Marketing  persons and entities. Defendant Charles Holley is an individual involved in the Direct  Marketing Industry, acting as a Direct Market Provider assisting Direct Marketing  entities. Defendant National Recall & Data Services Inc. obtains state motor vehicle  records from many state DMVs.    65. Defendant Naviss is a corporation involved in the Direct Marketing Industry, acting as  a Direct Market Provider assisting Direct Marketing persons and entities. Defendants  Logomasini and Chrisco are individuals involved in the Direct Marketing Industry.    66. The VSC Industry is the poster child for marketing abuses, illegal telemarketing,  and deceptive mailers. It is a complex financial infrastructure, funded by a  multitude of financial institutions. The core of their industry is “fueled” by illegally  obtaining millions of motor vehicle records from State Motor Vehicle  Departments, the “grease” to create and send the VSC marketing letters.  C. The Texas Department of Motor Vehicles conducted a covert investigation which  found undeniable proof that Defendants National Recall LLC. and NAVISS violated  7.   whether Defendant National Recall & Data Services Inc. and Defendant Charles  Holley acted knowingly when it obtained, re-disclosed, and/or resold Plaintiffs and  Class Member's personal information contained within motor vehicle records  maintained by the State motor vehicle departments;   8.   whether Defendant Naviss acted knowingly when it obtained, re-disclosed, and/or  resold Plaintiffs and Class Member's personal information contained within motor  vehicle records maintained by the State motor vehicle departments;   9.   whether Defendant National Recall & Data Services Inc. and Defendant Charles  Holley's conduct described herein violates the Driver's Privacy Protection Act, 18 