11.  After his in-person interview, Plaintiff was preliminarily hired for the  position to the results of his Criminal background check.     12.  Plaintiff has no criminal history.   13.   Having no criminal history, he did not anticipate any problem with his  background report.   14.  On September 19, 2015, Plaintiff contacted Lawson Little to advise of  his availability so she could plan accordingly for the drafting of the next schedule.   15.  In the meantime, Starbucks obtained and used a background report  prepared by Accurate Background, Inc. to make an employment decision regarding  Plaintiff.   16.  The consumer report provided to Starbucks included a statement that  Kevin W. Willis of Minnesota had been convicted twice of domestic violence.    Plaintiff has never used the name Kevin Willis and does not spell his name like  Kevin Willis, nor has he ever resided in Minnesota.   17.  The information was erroneously mixed into his information by  Starbucks Background reporting company.   19.  Indeed, Lawson Little explicitly stated that the criminal history on his  consumer report disqualified him from working for the coffee house.    20.  On September 22, 2015, Plaintiff received a letter from Accurate  Background, Inc. on behalf of Starbucks enclosing a copy of his background report.  This was days after being orally declined employment, in violation of  §1681b(b)(3)(A) of the FCRA.   21.  Mrs. Little provided Plaintiff with the telephone number of the  background company and called them to advise them of the error on or about  September 22, 2015.   22.  Starbucks routinely obtains and uses consumer reports, including  background reports, on its job applicants as part of a standard screening process.   23.  Starbucks typically does not provide job applicants with a copy of their  consumer reports before it takes adverse action against them based on the  information in such reports, despite being required to do so by §1681b(b)(3)(A) of  the FCRA.   25.  A primary reason that Congress required that a person intending to take  an adverse action based on information in a consumer report provide the report to  the consumer before taking the adverse action is so the consumer has time to review  the report and dispute information that may be inaccurate, or discuss the report with  the prospective employer before adverse action is taken. See Federal Trade  Commission letter dated December 18, 1997 to Harold R. Hawkey, Esq. (“[T]he  clear purpose of the provision to allow consumers to discuss reports with employers  or otherwise respond before adverse action is taken”).   27.  By means of these cases and others construing § 1681b(b)(3)(A),  Starbuck had substantial notice that its conduct violated the FCRA.   28.  By failing to provide Plaintiff and other Class members with copies of  their consumer reports prior to taking adverse action against them based on the  reports, Starbucks willfully disregarded the case law, regulatory guidance, and the  plain language of the FCRA, § 1681b(b)(3)(A).   29.  Starbuck’s conduct was a result of its deliberate policies and practices,  and was taken in reckless disregard for a consumer’s rights under the FCRA, and  further assumed an unjustifiably high risk of harm.   30.  Starbucks 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 Starbucks.  31.  Plaintiff reiterates each of the allegations in the preceding paragraphs  as if set forth fully herein. Plaintiff brings this action individually and as a class  action, pursuant to Rules 23(a) of the Federal Rules of Civil Procedure, on behalf of  the following Class:  All natural persons residing in the United States (including all  territories and other political subdivisions of the United States), who  had an adverse action taken against them by Starbucks during the Class  Period, based in whole or in part on a consumer report used for  employment purposes by Starbucks, and to whom Starbucks did not  provide a copy of the consumer report and a written description of  rights as provided in 15 U.S.C. § 1681b(b)(3)(A)(ii) at least five  business days before the adverse action was taken.   33.  The Class is so numerous that joinder of all members is impracticable. Although the  precise number of Class members is known only to Starbucks, Starbucks regularly  obtains and uses information in consumer reports to conduct background checks on  prospective employees and relies on such information, in whole or in part, as a basis  for adverse action. Starbucks’s website states that Starbucks operates over 25,000  locations worldwide. See https://news.starbucks.com/uploads/documents/AboutUs- Timeline-1.26.17.pdf. (last visited 08/10/2017).   35.  Plaintiff’s claims are typical of the claims of the Class, which all arise  from the same operative facts and are based on the same legal theories. Starbucks  typically uses consumer reports to conduct background checks on prospective  employees. Starbucks typically does not provide copies of consumer reports to  prospective employees before taking adverse action based on information in such  reports.   36.  Plaintiff will fairly and adequately protect the interests of the Class.  Plaintiff is committed to vigorously litigating this matter and has retained counsel  experienced in handling class actions and claims under the FCRA. Neither Plaintiff  nor her counsel has any interests that might cause them not to vigorously pursue this  claim.   38.  This action should be maintained as a class action because the  prosecution of separate actions by individual members of the Class would create a  risk of inconsistent or varying adjudications with respect to individual members  which would establish incompatible standards of conduct for the parties opposing  the Class, as well as a risk of adjudications with respect to individual members which  would as a practical matter be dispositive of the interests of other members not  parties to the adjudications or substantially impair or impede their ability to protect  their interests.  9.  Plaintiff applied in person for employment with Starbucks in  September 2015 at its Buford, Georgia store location.  