11.  On February 6, 2015, Plaintiff JEREMY MEYERS received from Defendant at  one of its retail establishments located at 501 Packerland Drive, Green Bay, Wisconsin 54303, a  computer-generated cash register receipt which displayed more than the last five digits of the  Plaintiff’s credit card number as well as the card’s expiration date.   12.  On February 10, 2015, Plaintiff JEREMY MEYERS received from Defendant at  one of its retail establishments located at 3120 South Packerland Drive, Green Bay, Wisconsin  54313, a computer-generated cash register receipt which displayed more than the last five digits  of the Plaintiff’s credit card number as well as the card’s expiration date.   13.  On February 17, 2015, Plaintiff JEREMY MEYERS received from Defendant at  one of its retail establishments located at 5939 Old Highway 29, Pulaski, Wisconsin 54162, a  computer-generated cash register receipt which displayed more than the last five digits of the  Plaintiff’s credit card number as well as the card’s expiration date.   14.  On information and belief, it is possible to replicate a card number using more  than the last five digits of the card number and the expiration date.  15.  Plaintiff brings this action on behalf of a Class pursuant to Fed.R.Civ.P. Rule  23(a) and (b)(3).   17.  The Class is so numerous that joinder of all individual members in one action  would be impracticable.  Since its first store opened in 1985, the Oneida Tribe has opened stores  in fifteen locations in northern Wisconsin.1  Many of the Oneida stores also contain casinos and  slot machines for visitors to use.2  The popularity of Oneida stores has helped them to become a  “profitable growing enterprise for more than twenty-five years.”3  Therefore, upon information  and belief, there are over 50 alleged FACTA violations at issue.   18.  Plaintiff’s claims are typical of the claims of the Class members.  All are based on  the same legal theories and arise from the same unlawful, negligent, reckless and/or willful  conduct.   20.  Plaintiff will fairly and adequately represent the Class members.  Plaintiff has no  interests that conflict with the interests of the Class members.  Plaintiff has retained experienced  counsel.   21.  A class action is superior to other available means for the fair and efficient  adjudication of the claims of the Class members.  Individual actions are not economically  feasible.  28.  29.  On information and belief, Defendant knew of the requirement concerning the  truncation of credit and debit card numbers and prohibition on printing of expiration dates, but  continued to print more than the last five digits of the card number and expiration dates anyway.   30.  On information and belief, VISA, MasterCard, American Express, the PCI  Security Standards Council—a consortium founded by VISA, MasterCard, Discover, American  Express and JCB—companies that sell cash registers and other devices for the processing of  credit or debit card payments, and other entities informed Defendant about FACTA, including its  specific requirements concerning the truncation of credit card and debit card numbers and  prohibition on the printing of expiration dates, and Defendant’s need to comply with the same.   31.  The truncation requirement was widely publicized among retailers.   32.  In May 2007, the Federal Trade Commission issued a business alert informing  businesses that they, “must delete the [credit and debit] card’s expiration date” and for example,  a receipt that truncates the credit card number and deletes the expiration date could look like this:  FACTA is a statute of general applicability, the statute does not interfere with tribal governance  or the rights granted to the tribe in other treaties, and Indian tribes are not specifically exempt  from the statute.   debit cards up to three years to comply with its requirements, requiring compliance for all  machines no later than December 4, 2006.  