10.  Equifax has not retrieved actual public records from courthouses or  actual government offices for many years.    11.  Nevertheless, on its credit reports that it provides to consumers, Equifax  falsely still lists the names of courthouses or other government offices as the true  “source” of its public records information.    12.  The public records information that Equifax receives from its vendors  are not the actual court or taxing authority records. Rather, it receives a distilled  version of those records, which does not include all the information or most up-to- date information available at the actual courthouses or government offices where the  true records are housed.   13.  Equifax knows that both it and its public records vendors make  mistakes in the distilled public records information that is acquired for purposes of  credit reporting.    15.  Defendant’s practices and procedures regarding the reporting of civil  judgment information, specifically its failure to report the most up-to-date status of  paid or satisfied civil judgments, causes widespread harm to Alabama consumers.    16.  Defendant also routinely fails to remove Alabama civil judgments from  consumers’ reports when those judgments have become nullities.    17.  In 2016 and 2017, Equifax delivered reports about Ms. Peters to  multiple end users, each of which used Equifax’s report to evaluate Ms. Peters’  creditworthiness. After the judgment was satisfied, Equifax continued to report the  judgment to several existing and potential creditors resulting in a negative impact on  Plaintiff’s credit standing regarding these transactions.    18.  More specifically, Plaintiff lost an opportunity to purchase a lawn  mower tractor at a fifty percent discount because of the inaccurate reporting on  Plaintiff’s Equifax consumer report.   19.  With respect to Ms. Peters, on or about March 29, 2011, judgment was  entered against Ms. Peters in favor of Corporate Billing, Inc. (hereafter “Corporate  Billing”) in Dale County, Alabama case number DV10-241, and in the original  amount of $5,207.51.   21.  On or about September 14, 2016, Full Satisfaction of Judgment was  filed in Dale County, Alabama case number DV10-241.   22.  On or about June 12, 2017, Ms. Peters requested and received a copy  of her personal credit report from Equifax. The Equifax credit report contained  inaccurate information, including but not limited to, reporting that Ms. Peters  allegedly had an outstanding civil judgment lodged against her in the amount of  $5,207.   23.  The civil judgment information Equifax included on Ms. Peters’ report  was woefully deficient. This civil judgment had been paid and satisfied more than  eight months earlier. Full Satisfaction of Judgment was filed in the public record for  the County of Dale, Alabama on September 14, 2016.   24.  Despite the Full Satisfaction of Judgment being recorded in the public  record, and pursuant to its usual and systematic practice, Defendant did not update  its records to show that the civil judgment had been paid and satisfied.   25.  The FCRA provides: “Whenever a consumer reporting agency prepares  a consumer report it shall follow reasonable procedures to assure maximum possible  accuracy of the information concerning the individual about whom the report  relates.” 15 U.S.C. § 1681e(b).    27.  The reporting of Ms. Peters’ civil judgment by Equifax was inaccurate  and occurred because Equifax failed to follow reasonable procedures to assure  maximum possible accuracy in the preparation of Ms. Peter’s consumer report.  Specifically, Equifax does not follow the same automated and systematically  rigorous processes to obtain all satisfactions and releases of civil judgments that it  follows to obtain the original civil judgment information.    28.  Indeed, Equifax follows no procedure which assures that, every time a  civil judgment in Alabama is paid or satisfied, the updated status is promptly  obtained and reflected upon the consumer’s credit report, or that the judgment is  removed from that consumer’s credit file.    30.  At all times pertinent hereto, Defendant was acting by and through its  agents, servants and or employees who were acting within the course and scope of  their agency or employment, and under the direct supervision and control of the  Defendant herein.   31.  Plaintiff realleges and incorporates by reference all preceding  paragraphs as alleged above.    32.  Plaintiff brings this action pursuant to the Federal Rules of Civil  Procedure 23(a) and 23(b)(3) on behalf of the following class:  All natural persons who: (i) had a civil judgment recorded in the State of  Alabama, (ii) the civil judgment appeared on an Equifax consumer report  dated within five years  prior to the filing of this Complaint, and (iii) the  State of Alabama public record indicated   that the civil judgment had been  paid or satisfied on a date prior to the date of the Equifax  consumer report.   33.  Plaintiff reserves the right to amend the definition of the Class based on  discovery or legal developments.    34.  Numerosity. FED. R. CIV. P. 23(A)(1). The Class members are so  numerous that joinder of all is impractical. Upon information and belief Defendant  sells hundreds if not thousands of consumer reports each year, and those persons’  names and addresses are identifiable through documents maintained by Defendant.    36.  Typicality. FED. R. CIV. P. 23(A)(3). Plaintiff’s claims are typical of  the claims of each Class member. Plaintiff has the same claims for statutory and  punitive damages as Class members, arising out of Defendant’s common course of  conduct.   37.  Adequacy. FED. R. CIV. P. 23(A)(4). Plaintiff is an adequate  representative of the Class. Her interests are aligned with and are not antagonistic  to, the interests of the members of the Class she seeks to represent, she has retained  counsel competent and experienced in such litigation, and she intends to prosecute  this action vigorously. Plaintiff and her counsel will fairly and adequately protect  the interests of members of the Class.    39.  Plaintiff incorporates by reference those paragraphs set out above as  though fully set forth herein.    40.  The above mentioned reports are “consumer reports” within the  meaning of 15 U.S.C. § 1681a(d).    42.  Pursuant to 15 U.S.C. §§ 1681n and o, Equifax is liable to Plaintiff and  all Class members for its failure to comply with FCRA § 1681e(b), in an amount  equal to the sum of (1) damages of not less than $100 and not more than $1,000 per  violation; (2) actual damages; (3) punitive damages in an amount to be determined  by the jury; (4) attorney’s fees; and (5) litigation costs, as well as such further relief  as may be permitted by law.   6.  Defendant is one of the “big three” credit reporting agencies (singular  “CRA”) in the United States.   7.  Defendant sells consumer reports (commonly called “credit reports”)  about millions of consumers annually, including consumers in Alabama.   9.  Upon information and belief, for several years Defendant has obtained  its information about Alabama and federal bankruptcies, civil judgments and tax  liens (i.e. “public records” information) from private businesses that it calls  “vendors,” which furnish such information to national CRAs.  