13.  Plaintiff brings this Class action on behalf of herself and all other persons  similarly situated pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure.    14.  The Class which Plaintiff seeks to represent is defined as:   All consumers to whom Defendant, within two years from the date of filing this  action, provided an electronically printed receipt at the point of a sale or  transaction at any of Defendant’s physical store locations, on which receipt  Defendant printed more than the last 5 digits of the consumer's credit card or debit  card (the “Class”).1   15.  Excluded from the Class are Defendant and its directors, officers, and employees.   16.  Numerosity (Fed. R. Civ. P. 23(a)(1)): The Class is so numerous that joinder of all  individual members in one action would be impracticable. The disposition of their claims  through this Class action will benefit both the parties and this Court.   17.  Plaintiff is informed and believes and thereon alleges that there are, at a  minimum, thousands (i.e., two thousand or more) of members that comprise the Class.   18.  The exact size of the Class and identities of individual members thereof are  ascertainable through Defendant’s records, including but not limited to Defendant’s sales and  transaction records.   20.  Typicality (Fed. R. Civ. P. 23(a)(3)): Plaintiff’s claims are typical of the claims of  the entire Class. The claims of Plaintiff and members of the Class are based on the same legal  theories and arise from the same unlawful conduct.    21.  Plaintiff and members of the Class were each customers of Defendant, each  having made a purchase or transacted other business with Defendant within two years from the  date of filing this action, using a credit card or debit card. At the point of such sale or transaction  with Plaintiff and members of the Class, Defendant provided to Plaintiff and each member of the  Class a receipt in violation of 15 U.S.C. §1681c(g) (i.e., a receipt on which is printed more than  the last 5 digits of the credit card or debit card).   22.  Common Questions of Fact and Law (Fed. R. Civ. P. 23(a)(2) and (b)(3)): There  are a well-defined community of interest and common questions of fact and law affecting the  members of the Class.   24.  Adequacy of Representation (Fed. R. Civ. P. 23(a)(4)): Plaintiff is an adequate  representative of the Class because her interests do not conflict with the interests of the Class  which Plaintiff seeks to represent. Plaintiff will fairly, adequately, and vigorously represent and  protect the interests of the Class and has no interests antagonistic to the Class. Plaintiff has  retained counsel who is competent and experienced in the prosecution of Class action litigation.   25.  Superiority (Fed. R. Civ. P. 23(b)(1) and 23(b)(3)): A Class action is superior to  other available means for the fair and efficient adjudication of the claims of the Class. While the  aggregate damages which may be and if awarded to the Class are likely to be substantial, the  actual damages suffered by individual members of the Class are relatively small. As a result, the  expense and burden of individual litigation makes it economically infeasible and procedurally  impracticable for each member of the Class to individually seek redress for the wrongs done to  them.   26.  Plaintiff hereby incorporates by reference the allegations contained in this  Complaint.   27.  Plaintiff asserts this claim on behalf of herself and the Class against Defendant.   29.  By its express terms, 15 U.S.C. § 1681c(g)(1) applies to “any cash register or  other machine or device that electronically prints receipts for credit card or debit card  transactions” after December 3, 2006. 15 U.S.C. § 1681c(g)(3).    3.  The law gave merchants who accept credit and or debit cards up to three years to  comply with its requirements, requiring full compliance with its provisions no later than  December 4, 2006. Although Defendant had up to three years to comply, Defendant willfully  violated this law and failed to protect Plaintiff and others similarly situated against identity theft  and credit and debit card fraud by printing more than the last 5 digits of the card number on  receipts provided to credit card and debit card cardholders transacting business with Defendant.  This conduct is in direct violation of FACTA.   30.  Defendant transacts business in the United States and accepts credit cards and  debit cards in the course of transacting business with persons such as Plaintiff and members of  the Class. In transacting such business, Defendant uses cash registers and or other machines or  devices that electronically print receipts for credit card and debit card transactions.    31.  After December 3, 2006, and within two years from the date of filing this action,  Defendant, at the point of a sale or transaction with Plaintiff Joan Pasini, provided Plaintiff Joan  Pasini with one or more electronically printed receipts on each of which Defendant printed more  than the last 5 digits of her credit card number.  More specifically, Defendant printed the first 6  digits and the last 4 digits of Plaintiff Joan Pasini’s credit card number on her customer  receipt(s).     32.  After December 3, 2006, and within two years from the date of filing this action,  Defendant, at the point of a sale or transaction with members of the Class, provided each  member of the Class with one or more electronically printed receipts on each of which  Defendant printed, for each respective Class member, more than the last 5 digits of their credit  card or debit card number.    34.  Defendant knew of and was well informed about the law, including specifically  35.  For example, but without limitation, several years ago, VISA, MasterCard, the  PCI Security Standards Council (a consortium founded by VISA, MasterCard, Discover,  American Express and JCB), companies that sell cash register and other devices for the  processing of credit or debit card payments, companies that sell software to operate payment  card devices, companies that maintain and repair hardware or software used to process payment  card transactions, and other entities informed Defendant about FACTA, including its specific  requirements concerning the truncation of credit and debit card numbers and prohibition on the  printing of expiration dates, and Defendant's need to comply with same.    36.  Other entities, including but not limited to Defendant’s merchant bank (also  known as the acquiring bank or acquirer) which processes credit and debit card payments for  transactions occurring at Defendant’s stores, likewise informed Defendant about FACTA,  including its specific requirements concerning the truncation of credit and debit card numbers  and prohibition on the printing of expiration dates, and Defendant’s need to comply with same.    4.  Nor is Defendant’s willful violation of FACTA a trifling matter. In the statement  provided during his signing of FACTA in 2003, the President underscored the importance of the  legislation in combating rampant identity theft:   This bill also confronts the problem of identity theft. A growing number of  Americans are victimized by criminals who assume their identities and cause  havoc in their financial affairs. With this legislation, the Federal Government is  protecting our citizens by taking the offensive against identity theft.   44.  Defendant knowingly, willfully, intentionally, and recklessly violated FACTA in  conscious disregard of the rights of Plaintiff and the Class.   45.  Defendant has also harmed Plaintiff and the Class by exposing them to at least an  increased risk of identity theft and credit and or debit card fraud.    5.  Courts have likewise emphasized the purpose of FACTA. For example, the Ninth  Circuit recently emphasized that “[i]n fashioning FACTA, Congress aimed to ‘restrict the  amount of information available to identity thieves.’” Bateman v. American Multi-Cinema, Inc.,  623 F.3d 708, 718 (9th Cir. 2010) (quoting 149 Cong. Rec. 26,891 (2003) (statement of Sen.  Shelby)).    6.  Similarly, the Seventh Circuit recently explained that “[i]dentity theft is a serious  problem, and FACTA is a serious congressional effort to combat it.” Redman v. Radioshack  Corp., 768 F.3d 622, 639 (7th Cir. 2014).   For Violation of 15 U.S.C. §§ 1681 et seq.  (On Behalf of Plaintiff and the Class as against Defendant)   prohibition on the printing of expiration dates.    receipts in violation of FACTA.   