29. Without a brick-and-mortar store, most online payday and other predatory lenders rely heavily on marketing and advertising to prey on consumers.^  31. Lead generators pay high fees to several sources to acquire borrower information, including consumer reporting agencies. Often, lead generators use a non-Big 3^ consumer reporting agency, such as Clarity, because ofit does not impose the demanding verification and "permissible purpose" restrictions like the Big-3. rits lax policies and procedures which do not meaningfully attempt to limit the furnishing of consumer reports for the purposes listed in § 1681b.  32. Lead generators primarily obtain the consumer reports to review consumers' personal fmancial information in order to obtain details of the consumers' lifestyle, mode of living, whether the consumer has recently applied for other subprime credit and other evidence ofa vulnerability to high cost credit.  33. In turn, lead generators then auction the consumer information to lenders who make predatory loans or to intermediary databrokers, who thenre-sell the leads to such lenders.  34. Typically, lead generators resell the same applicant's information to other companies after an exclusivity period for the "first-look buyer," who pays a higher cost for a briefexclusivity periodin orderto be the first lenderto contactthe consumer.  35. Often times, lists—such as a list of people who have applied for payday loans— are soldand then resoldby brokers, especially if a company does not wishto makea loan.  36. Ultimately, this practice leads to instantaneous harassment and solicitation by numerous online lenders and data brokersas soonas a consumer appliesfor a singleonline loan.  38. As reflected by the credit reports of the named Plaintiffs, this results in the improper access ofa consumer's credit report bymultiple entities formonths, often years, after a consiuner applies for a smgle internet loan by entities that a consumer never contacted, nor authorized to obtain their private financial details.  39. As reflected by the credit reports of the named Plaintiffs and confirmed by other facts known to the Plaintiffs and their counsel, this same lead generator scheme as outlined in the above paragraphs waspresent andmade available against each of thenamed Plaintiffs because of and by Clarity.  40. Clarity knowingly participates in this scheme despite its knowledge of the requirements of §§ 1681b and 1681e(a). In sum, Clarity impermissibly accesses consumer reports (often on multiple occasions) from Experian without having a permissible purpose under the FCRA to collect information on consumers seeking Internet payday loans. Then, Clarity resells and provides access to this data to companies that it knew or should have known were lead generators or data brokers, often times at rapid speeds that would ordinarily serve as wammgs signs ofthe misuse ofconsumer reports. Common Allegations as to Clarity  42. Clarity holds itselfoutasa credit reporting agency that"provides information that is not available from traditional reporting agencies, and assists lenders in gaining a competitive advantage by viewing subprime consumer data."^  43. As part of this process. Clarity permits access to its consumer database for impermissible purposes, primarily to allow its customers to identify potential payday lending opportunities and then sell the identities of thoseconsumers as "leads".  44. Clarity either knew or should have known that entities specifically identified below were accessing its consumer reports to generate leads.  45. By way of example, and without limitation. Clarity could have discovered with minimal Internet research and/or an onsite visit that the following companies were lead generators; Clickspeed, Lead Express, 123 CashDepot, Inc.,and SonicCash.  46. Moreover, upon information and belief, "The Servicing Company" is also a lead generator and/or a "ghost company". If a minimal investigation was conducted, Clarity would have discoveredthat The Servicing Company was an impermissible user ofconsumer reports.  47. Hereafter, Clickspeed, Lead Express, 123 Cash Depot, Inc., Sonic Cash, and The Servicing Company are collectively referred to as the "Impermissible Users".  48. As a consumer reporting agency focusing on subprime lendmg. Clarity understands the nature of lead generating and that such companies often impermissibly access consumer reports as a means of generating leads.  50. For example, upon information and belief, Clarity does not have any vetting process to verify the identity of new prospective users prior toallowing them toobtain consumer reports from its database. Instead, upon information and belief, Clarity will allow any ornearly any company to access itsconsumer report solong asthatcompany iswilling to pay a fee for the consumer report.  51. Upon information and belief, Clarity does not perform basic research on its users or make reasonable efforts to visit a prospective user's business location to ensure that the prospective company isa reliable andlegitimate user of Clarity's database.  52. Upon information and belief, no investigation is performed by Clarity to determine a company's legitimacy or reliability even though Clarity knows that lead generation andmass marketing companies with no legitimate reason to obtain consumer reports frequently use Clarity's consumer reports as a means of obtaining private, financial information on consumers.  53. In addition. Clarity regularly permits illegitimate companies to access the consumer reports of consumers dozens of times within a single hour. Where such repeated uses would ordinarily serve as warning signs of misuse of consumer reports, Clarity continued to allow unfettered access to its database without consideration ofthese unusual use patterns.  55. Moreover, each time Clickspeed accessed Ms. Tumage's consumer report— which occurred at least 19 times in less than a month—Clickspeed entered the same "permissible" purpose code, which signified that Clickspeed's purpose for obtaining Ms. Tumage's consumer report was a "pre-check."  56. Clarity defines this purpose as "a request to find a creditor, through a lead generator that was initiated by you."  57. This is not one of the permissible purposes established in § 1681b(a). Moreover, given the frequent use of Clarity's database by Clickspeed and other similar entities. Clarity knew or should have known that its consumer reports were not being obtained for a permissible purpose because such conduct and the stated purposes were entirely inconsistent with the permissiblepurposes established in § 1681b(a).  58. Upon information and belief, even after the frequent use of Clarity's database, it still does not investigate any of its users, nor has it ever prohibited any user from accessing its database.  59. Moreover, given the fi-equent use of Clarity's database by Clickspeed and other similar entities. Clarity should have identified the repeated use of its database as a "red flag" and prohibited such companies from accessing its database. This is especially true given the known business purpose of Clickspeed and the other Impermissible Users as leadgeneration companies and not actual lenders engaging in credit transactions with the named Plaintiffs.  61. In doing so. Clarity also further violated of 1681b(a), as well as § 1681e(a), which prohibits a consumer reporting agency from furnishing a consumer report if it has "reasonable grounds for believing that the consumer report willnot be used for a purpose" listed in § 1681b.  62. Moreover, in order to be more valuable to such companies. Clarity repeatedly obtains consumer reports from Experian Information Solutions, Inc. ("Experian") so that it can incorporateExperian's databases into its own records.  63. Clarity did not have a lawful piupose to obtain and use the Plaintiffs' credit reports andthePlaintiffs never authorized Clarity to receive their credit reports.  64. Clarity's disclosed purposes for the sale of its consumer reports - "PC" for Pre- Check and "AR" for new credit were uniformly false. Neither signified an actual existing credit "accountreview", new creditapplication specifically initiatedby the consumer or a pre-approved firm offer ofcredit governed by the FCRA.  65. Further, upon information and belief, because Clarity does not even know the identity of the "end-user" for which the Experian information could be used - the Internet payday lender that will ultimately purchase the data from the Impermissible User or lead generator - it didnotandcould possible have made thedisclosures required by § 1681e(e) when it obtained for resale information from Experian.  67. In April 2013, Ms. Tumage sent correspondence to Clarity requesting a copy of her consumer disclosure.  68. On or about April 29, 2013, Clarity forwarded Ms. Tumage a copy of her consumer report.  69. Ms. Tumage's Clarity consumer report contained forty-three inquiries from Clickspeed that werecoded"PC" for Pre-Check. Someof these Clickspeed inquiries werewithin seconds of one another. There were also four inquires for The Servicing Company that were coded "AR" for new credit. There was one inquiry each for Lead Express and 123 Cash Depot, Inc., that were coded as "AR" for new credit even though neither of these companies are lenders. All of these inquiries were coded as "Cl" or "C3" identifying an Intemet payday loan and Intemet unsecured loan respectively.  70. Upon review of her report, Ms. Tumage identified inaccurate tradeline information in her Clarity consumer report.  71. On or about October 9, 2013, Ms. Tumage sent correspondence to Clarity requesting that they remove the inaccurate information in her Clarity consumer report.  72. In correspondence dated October 29, 2013, Clarity responded that it would not investigate her disputeand informedMs. Tumage that it "determinedyour disputeis frivolous."  73. In subsequent correspondence dated November 15, 2013, Clarity removed the inaccurate tradeline information in Ms. Tumage's Clarity consumer report.  74. On or about February 21, 2013, Ms. Tumage obtained a copy of her Experian consumer disclosure which identified seven impermissible pulls by Clarity.  76. On or about May 9, 2014, Mr. Gillison sent correspondence to Clarity requesting a copy ofhis consumer report.  77. Onor about May 19,2014,Clarity forwarded Mr. Gillison a copy of hisconsumer report.  78. Mr. Gillison's Clarity consumer report contained eleven inquiries including four inquiries from Clickspeed that were coded "PC" for Pre-Check. These four Clickspeed inquiries all occurred on September 6,2013 withinseconds of one another.  79. There was also one inquiry each for Lead Express that was coded as "AR" for new credit. All ofthese inqumes were coded as"Cl" or"C3"identifying aninternet payday loan and internet unsecured loan respectively. Facts as to Polly Larimer  80. On or about September 27, 2014, Ms. Larimer sent correspondence to Clarity requesting a copy ofher consumer report.  81. On or about October 4, 2013, Clarity forwarded Ms. Larimer a copy of her consumer report. Clarity did not provide any documentation with her consumer report defining anyofthe codes to enable herto understand whatwasin her consumer report.  82. Ms. Larimer's Clarity consumer report contained a Clickspeed inquiry that was coded "PC" for Pre-Check.  83. Upon review of her report, Ms. Larimer identified inaccurate tradeline information in her Clarity consumer report.  85. Clarity did not respond to Ms. Larimer's correspondence.  86. On or about September 27, 2013, Ms. Larimer obtained a copy of her Experian consumer disclosure which identified eleven impermissible pulls by Clarity.  87. At no time did Ms. Larimer receive an offer of credit from Clarity, have a credit relationship with Clarity, or give Clarity permission to obtain a copy ofher credit report. Facts as to Carshena Jackson  88. On or about October 10, 2013, Ms. Jackson sent correspondence to Clarity requesting a copy ofher consumer report.  89. On or about October 21, 2013, Clarity forwarded Ms. Jackson a copy of her consumer report. Clarity did not provide any documentation with her consumer report defining any ofthe codes to enable her to understand what was in her consumer report.  90. Ms. Jackson's Clarity consumer report contained one inquiry from Clickspeed that was coded "PC" for Pre-Check.  91. Upon review of her report, Ms. Jackson identified inaccurate tradeline information in her Clarity consumer report.  92. On or about November 4, 2013 Ms. Jackson sent correspondence to Clarity requesting that they remove the inaccurate information in her Clarity consumer report.  93. Clarity did not respond to Ms. Jackson's correspondence. Facts as to Michelle Campbell  95. On or about December 4, 2013, Clarity forwarded Ms. Campbell a copy of her consumer report. Clarity did not provide any documentation with her consumer report defining any of the codesto enable herto understand whatwas in her consumer report.  96. Ms. Campbell's Clarity consumer report contained thirteen inquiries from Clickspeed thatwere coded "PC" for Pre-Check. Some of these Clickspeed inquiries were within seconds ofone another. There was also one inquiry from The Servicing Company.  97. On or about January 11, 2014, Ms. Campbell obtained a copy of her Experian consumer disclosure which identified twelve impermissible pulls by Clarity.  98. At no time did Ms. Campbell receive an offer of credit from Clarity, havea credit relationship with Clarity, or giveClarity permission to obtain a copy of her credit report. Facts as to Sharon Holmes  OverviewofLead Generation 