 (Count I:  15 U.S.C. § 1681b(b)(1))   11.  Several courts have held that prospective, blanket certifications obtained by a  consumer reporting agency from a user do not comply with 15 U.S.C. § 1681b(b) because they  run counter to Section 1681b(b)(1)’s use of the phrase “has complied,” which refers  retrospectively to an action already taken.  See, e.g., Syed v. M-I LLC, No. 1:14-742-WBS-BAM,  2014 WL 5426862, at **4-5 (E.D. Ca. Oct. 23, 2014); Robles v. Ampam Parks Mechanical, Inc.,  No. 14-02362-VAP, 2015 WL 1952311, at **4-5 (C.D. Ca. Apr. 28, 2015).  Background Reports Furnished by Defendant   12.  In August 2014, Plaintiff applied for a job with CA Ventures, LLC in  Washington.   13.  On or about August 8, 2014, CA Ventures, LLC, through Campus Acquisitions  Investment Management LLC, procured or caused to be produced a consumer report regarding  Plaintiff from Defendant.   14.  On or about August 8, 2014, Defendant furnished Plaintiff’s consumer report to  Campus Acquisitions Investment Management LLC.   15.  The consumer report stated:   Your acceptance and use of this report constitutes your certification that  you are in full compliance with the Fair Credit Reporting Act (15 U.S.C.  Section 1681 et seq., as amended) and all applicable state and federal  laws, including but not limited to state and federal equal employment  opportunity laws.  Prior to requesting or using this report, clients must  have signed a Statement of Terms and Conditions certifying that users are  familiar with, will abide by and will use the report in compliance with all  applicable laws, including but not limited to, the Fair Credit Reporting  Act.   17.  Upon information and belief, at all times relevant to this action, Defendant has  required the users to whom it furnishes a consumer report to sign a Statement of Terms and  Conditions, which requires that the user prospectively certify that it will comply with the Fair  Credit Reporting Act, including Section 1681b(b)(1).   18.  Defendant violated Section 1681b(b)(1) by furnishing consumer reports regarding  Plaintiff and other class members for employment purposes without first obtaining from the  persons who obtained such report a certification that such person “has complied with paragraph  (2) [of Section 1681b(b)] with respect to the consumer report, and the person will comply with  paragraph (3) with respect to the consumer report if paragraph (3) [of Section 1681b(b)] becomes  applicable.”   19.  Defendant knew or should have known about its legal obligations under the  FCRA. The language of Section 1681b(b)(1) is plain and clearly ascertainable. According to  Section 1681b(b)(1)(A), a “consumer reporting agency may furnish a consumer report for  employment purposes only if -- (A) the person who obtains such report from the agency certifies  to the agency that-- (i) the person has complied with paragraph (2) with respect to the consumer  report, and the person will comply with paragraph (3) with respect to the consumer report if  paragraph (3) becomes applicable; and (ii) information from the consumer report will not be used  in violation of any applicable Federal or State equal employment opportunity law or regulation.”  (Emphasis added.)   21.  Defendant knew or should have known about its legal obligations under the  FCRA. These obligations are well established in the plain language of the FCRA, in the  promulgations of the Federal Trade Commission, and in well-established case law. Defendant  obtained or had available substantial written materials that apprised it of its duties under the  FCRA. Any reasonable consumer reporting agency knows about or can easily discover these  obligations.   22.  Despite knowing of these legal obligations, Defendant intentionally or recklessly  acted consciously in breaching its known duties and depriving Plaintiff and other Class members  their rights under the FCRA. Plaintiff believes that Defendant did not obtain proper and valid  certifications before furnishing consumer reports to its clients because Defendant did not want to  incur the expenses associated with obtaining such certifications as to each consumer as to whom  a consumer report was generated and provided by Defendant.   23.  As a result of these FCRA violations, Defendant is liable for statutory damages  from $100 to $1,000 for each violation pursuant to 15 U.S.C. § 1681n(a)(1)(A), punitive  damages pursuant to 15 U.S.C. § 1681n(a)(2), and attorney’s fees and costs pursuant to Section  1681n and Section 1681o.  25.  Numerosity:  The members of the Class are believed to be in excess of 100,000  and are so numerous that joinder of all members is impractical. The names and addresses of the  Class members are identifiable through documents maintained by the Defendant, and the Class  members may be notified of the pendency of this action by published and/or mailed notice.   26.  Typicality:  Plaintiff’s class claims are typical of the claims of Class members.  Plaintiff for class certification purposes seeks only statutory and punitive damages. In addition,  Plaintiff is entitled to relief under the class claims as the other members of the Class.   27.  Adequacy:  Plaintiff is an adequate representative of the Class because Plaintiff’s  interests coincide with, and are not antagonistic to, the interests of the members of the Class  Plaintiff seeks to represent. Plaintiff has retained counsel competent and experienced in class  action litigation, and Plaintiff intends to prosecute this action vigorously. The interests of  members of the Class will be fairly and adequately protected by Plaintiff and Plaintiff’s counsel.     29.  Superiority:  Questions of law and fact common to the Class members  predominate over questions affecting only individual members, and a class action is superior to  other available methods for fair and efficient adjudication of the controversy. The statutory and  punitive damages sought by each member are such that individual prosecution would prove  burdensome and expensive given the complex and extensive litigation necessitated by  Defendant’s conduct. It would be virtually impossible for the members of the Class individually  to redress effectively the wrongs done to them. Even if the members of the Class themselves  could afford such individual litigation, it would be an unnecessary burden on the Courts.  Furthermore, individualized litigation presents a potential for inconsistent or contradictory  judgments and increases the delay and expense to all parties and to the court system presented by  the complex legal and factual issues raised by Defendant’s conduct. By contrast, the class action  device will result in substantial benefits to the litigants and the Court by allowing the Court to  resolve numerous individual claims based upon a single set of proof in a case.  30.  Plaintiff realleges Paragraph Nos. 1-29 as if fully set forth herein.   32.  By failing to obtain the required specific certification from persons to whom  Defendant furnished consumer reports as to each consumer report provided before providing the  specific consumer report that was the subject of the certification, Defendant violated the express  requirement of Section 1681b(b)(1).    33.  The foregoing violations were willful.  Defendant knew or should have known  about its obligations under the FCRA.     34.  Plaintiff and the Certification Class members are entitled to statutory damages of  not less than $100 and not more than $1,000 for each and every one of these violations, pursuant  to 15 U.S.C. § 1681n.   35.  Plaintiff and the Certification Class members are also entitled to recover their  costs and attorneys’ fees, pursuant to 15 U.S.C. § 1681n(a)(3).  9.  15 U.S.C. § 1681b(b) regulates the conduct of “persons” who furnish, use,  procure or cause to be procured a “consumer report” for employment purposes as follows:   (b) Conditions for furnishing and using consumer reports for  employment purposes  (1) Certification from user   A consumer reporting agency may furnish a consumer report for  employment purposes only if –   (A) the person who obtains such report from the agency certifies to  the agency that—  (i) the person has complied with paragraph (2) with respect  to the consumer report, and the person will comply with  paragraph (3) with respect to the consumer report if  paragraph (3) becomes applicable; and   (ii) information from the consumer report will not be used  in violation of any applicable Federal or State equal  employment opportunity law or regulation; and   (B) the consumer reporting agency provides with the report, or has  previously provided, a summary of the consumer’s rights under  this subchapter, as prescribed by the Bureau under section  1681g(c)(3) of this title.   The Statutory Landscape  