18. At all times relevant, Plaintiff is and was an individual residing within the  State of California.   29. Plaintiff brings this action on behalf of himself and on behalf of all others  similarly situated (the “Class”).   30. Plaintiff represents, and is a member of the Class, consisting of:   All persons within the United States of America  whose consumer credit report from Transunion was  provided to the consumer by means other than in  writing without the consumers’ specification or  authorization within the five-year period prior to the  filing of Plaintiff’s Complaint.   31. Defendant and its employees or agents are excluded from the Class.  Plaintiff does not know the number of members in the Class, but believes  the Class members number in the several hundreds, if not more. This matter  should therefore be certified as a Class action to assist in the expeditious  litigation of this matter.    32. Plaintiff and members of the Class were harmed by the acts of Defendant in  at least the following ways: Defendant, either directly or through its agents,  engaged in unlawful practices, when it provided Plaintiff with a free annual  consumer report in the form of two (2) audio CD’s without Plaintiff’s  specification or authorization to make the disclosure by such alternative  means under 15 U.S.C. §§ 1681 et seq.  Plaintiff and the Class members  were damaged thereby.    41. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   THE FAIR CREDIT REPORTING ACT  15 U.S.C. §§ 1681-1692X (FCRA)  