29.  During the class period, Defendant furnished an employment-purposed consumer  report concerning Plaintiff to a third party, Pinkerton Consulting & Investigations, which in turn  sold the report to Ms. Doe’s employer, Trinity.   30.  Among other things, the FCRA regulates the collection, maintenance, and  disclosure of consumer credit report information by consumer reporting agencies (CRAs),  including public record information.   31.  Additionally, the FCRA mandates conditions, procedures, and limitations on the  use of consumer reports for employment purposes by prospective employers and other individuals.   32.  The FCRA mandates that a report user, before taking any adverse action based in  whole or in part on a consumer report, must provide to the consumer a copy of the applicant’s  report and a summary of the applicant’s rights under the FCRA.   33.  Innovative and Pinkerton are parties to an agreement whereby Innovative furnishes  customized, employment-purposed consumer reports about consumers, including but not limited  a report known as the “NATCRIM.”     34.  Under the FCRA, Pinkerton must certify that each consumer report it requests is  for a permissible purpose.     36.  Innovative has an independent obligation to comply with the FCRA.     37.  Innovative’s violations of the FCRA have been willful, wanton, and reckless in that  it knew, or should have known, that it was failing to comply with the requirements of the FCRA.   38.  Innovative willfully disregards its duties under the FCRA, which it exacts serious  consequences on job applicants and interstate commerce. The natural result of Innovative’s failures  to abide by the conditions, procedures and limitations of the FCRA prejudices consumers’ ability  to challenge information contained in consumer reports it sells to third parties.     39.  Innovative does not provide notification to consumers that it furnished an  employment-purposed consumer report containing a criminal record likely to adversely affect  employment at the time it provides the report to third parties.     40.  Innovative expressly disclaims that it is providing consumer reports for  employment purposes, yet it knowingly supplies such reports to third parties that it knows uses the  reports for employment purposes.    75.  Plaintiff brings this action on a class basis, with initial class definitions that follow.   76.  The § 1681k(a)(1) Notice Class, on or after August 25, 2015.  Pursuant to Federal  Rule of Civil Procedure 23 and 15 U.S.C. § 1681k, Plaintiff brings this action for themselves and  on behalf of the following “Notice Class,” of which she is a member, initially defined as:  All natural persons residing in the United States (including all territories and other  political subdivisions of the United States) (a) who were the subject of a consumer  report issued after August 25, 2015, (b) that was furnished by Innovative to a third  party, (c) that contained at least one public record of a criminal conviction or arrest,  and (d) to whom Innovative did not place in the United States mail postage pre- paid, on the day it furnished the report, a written notice that it was furnishing the  subject report and containing the name of the person that was to receive the report.    78.  Numerosity.  Upon information and belief, the putative Classes exceed 50  members each.  Information concerning the exact size of the putative Class is within the exclusive  possession of Defendant or its agents.   79.  The Class members are so numerous that joinder of all members is impracticable.   80.  Typicality. Plaintiff’s claims are typical of the claims of the other Class members  as all Class members were similarly affected by Defendant’s unlawful conduct in violation of the  87.  Plaintiff incorporates by reference those paragraphs set out above as though fully  set forth herein.   88.  The consumer report of the Named Plaintiff and of each member of the “Notice  Class” was furnished for an employment purpose and contained one or more public records of the  type that may adversely affect an employer’s hiring decision.   90.  On information and belief, Plaintiff alleges that Innovative obtains public records  including criminal records from a third-party consumer reporting agency and does not attempt to  obtain this information through its own courthouse searches.   91.  On information and belief, Plaintiff alleges that as to the “Notice Class,” Innovative  did not send such class members a notice pursuant to 15 U.S.C. § 1681k(a)(1).   92.  On information and belief, Plaintiff alleges that as to the “Notice Class,” Innovative  did not itself or by its own court researchers or vendors attempt to verify the completeness or  current status of the public records pursuant to 15 U.S.C. § 1681k(a)(2), within 30 days before it  furnishes and sells these records in one of its reports.   93.  Innovative’s failure to timely provide the required FCRA notices to the Plaintiff  and other members of the “Notice Class” violated 15 U.S.C. § 1681k(a)(1).   94.  The conduct, action, and inaction of Defendant was willful, rendering it liable for  statutory and punitive damages in an amount to be determined by the Court pursuant to 15 U.S.C.  § 1681n.   95.  Plaintiff and other members of the putative “Notice Class” are entitled to recover  costs and attorneys’ fees as well as appropriate equitable relief from Innovative in an amount to  be determined by the Court pursuant to 15 U.S.C. § 1681n.  96.  Plaintiff reiterates each of the allegations in the preceding paragraphs as if set forth  herein at length.     98.  Innovative also included obsolete information – for instance, records of arrests  antedating the report by more than seven years – in the consumer reports it sold to third parties  about the putative class members.     99.  Defendant violated 15 U.S.C. § 1681c(a)(2) by reporting arrest information that  was not only expunged, it obviously antedated the report by more than seven years.    100.  Defendant knew that it was forbidden by the FCRA to publish criminal arrest  information in a consumer report that is older than seven years, but despite this knowledge  published the obsolete information anyway.    101.  As to the Named Plaintiff and the “Obsolete Information Class,” Innovative  regularly violates the prohibition on publishing obsolete information in violation of 15 U.S.C. §  1681c(a)(2).   102.  As a result of the publication of obsolete information, the Named Plaintiff and the  “Obsolete Information Class” were subjected to the publication of information that was deemed  obsolete by Congress and specially excluded from information permitted in consumer reports.    103.  The conduct, action, and inaction of Innovative was willful, rendering it liable for  statutory and punitive damages in an amount to be determined by the Court pursuant to 15 U.S.C.  § 1681n.  104.  Plaintiff and other members of the putative “Obsolete Information Class” are  entitled to recover costs and attorneys’ fees as well as appropriate equitable relief from Innovative  in an amount to be determined by the Court pursuant to 15 U.S.C. § 1681n.   Failure To Provide “At The Time” Notice – 15 U.S.C. § 1681k(a)(1)   Obsolete Information – 15 U.S.C. § 1681c(a)   Plaintiffs’ Proposed Classes  