15 U.S.C. § 1681, et seq.  On behalf of Plaintiff and the Class   37.  On April 29, 2018, Plaintiff took a tour of Atlas Apartments (“Atlas”), a modern  apartment complex located at 1036 7th Avenue NW, Issaquah, Washington 98027.    65.  Class Definition: Plaintiff brings this action pursuant to Federal Rule of Civil  Procedure 23(b)(2) and 23(b)(3) on behalf of himself and a class defined as follows:  All persons in the United States who: (1) were the subject of a consumer  report provided by RentGrow; (2) containing a reappearance of previously  corrected inaccurate information; (3) about residential or tenant payment  history.  The following people are excluded from the Class: (1) any Judge or Magistrate presiding  over this action and members of their families; (2) Defendant, Defendant’s subsidiaries, parents,  successors, predecessors, and any entity in which Defendant or its parent has a controlling  interest and their current or former employees, officers and directors; (3) Defendant’s insurer or  its parent having a controlling interest and their current or former employees, officers and  director; (4) persons who properly execute and file a timely request for exclusion from the Class;  (5) persons whose claims in this matter have been finally adjudicated on the merits or otherwise  released; (6) Plaintiff’s counsel and Defendant’s counsel; and (7) the legal representatives,  successors, and assigns of any such excluded persons.   66.  Numerosity: The exact number of members in the Class is unknown and not  available to Plaintiff, but it is clear that individual joinder is impracticable. On information and  belief, hundreds or thousands of consumers fall into the definition of the Class based on  Defendant’s volume of business. Members of the Class can be identified through Defendant’s  records.   72.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.   73.  15 U.S.C. § 1681e(b) states that “[w]henever 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.”   74.  Defendant is a consumer reporting agency that prepares consumer reports for  third parties by preparing tenant screening reports that contain consumer’s residential or tenant  history.   75.  Defendant failed to establish or follow reasonable procedures to assure maximum  possible accuracy of the information concerning Plaintiff and each member of the Class in  violation of 15 U.S.C. § 1681e(b).   76.  At all relevant times, Defendant failed to establish or follow reasonable  procedures to prevent previously deleted inaccurate information about residential or tenant  history from reappearing on its consumer reports about Plaintiff and each member of the Class in  violation of 15 U.S.C. § 1681e(b).  