10.  Plaintiff has never been convicted of any sex crimes and has never registered as a  sex offender anywhere.   11.  In fact, Plaintiff has historically worked as a driver transporting medical patients,  usually elderly, between various locations and his criminal background history, even as it applies  to something as simple as traffic infractions, is very important to him.   13.  In late 2018, Plaintiff requested the disclosure of all the information in his  consumer file from the Defendant.   14.  Plaintiff wrote to the Defendant to seek a copy of this information.   15.  In this letter, Plaintiff provided the Defendant with everything that it would need  to identify him, including his First Name, Last Name, Generational Suffix, Street Address, City,  State, Zip Code, and Date of Birth.   16.  The Defendant regularly sells reports to its customers that provide the Defendant  with less information than this.   17.  Upon information and belief, the Defendant will sell criminal background reports  to its customers that provide nothing more than a full name and a date of birth for the subject of  the requested report.   18.  The Plaintiff also provided the Defendant with a valid copy of his driver's license.   19.  The Defendant responded to the Plaintiff on September 27, 2018.    20.  The Defendant was able to identify the Plaintiff using the information that he  provided with his dispute as described above.   21.  The Defendant did not have any trouble or difficulty understanding who the  Plaintiff was.   22.  The Defendant would have sold a report about the Plaintiff to any of its customers  that requested it on September 27, 2018.   24.  The Defendant's response also did not contain "the sources of the information", as  required by 15 U.S.C. §1681g(a)(2).   25.  The Defendant's response also did not contain the "identification of each  person...that procured a consumer report" about the Plaintiff for employment purposes within the  preceding 2-year period, or for any other purpose during the preceding 1-year period, as required  by 15 U.S.C. §1681g(a)(3)(A).   26.  In fact - the Defendant's response did not contain anything relevant to the  Plaintiff, and entirely failed to comply with 15 U.S.C. §1681g.   27.  Instead, the Defendant responded by sending the Plaintiff a “Copy Request  Form”, attached hereto as Exhibit "A", to complete and return before it would agree to provide  him with the disclosure required by 15 U.S.C. §1681g.   28.  The "Copy Request Form" required Plaintiff to (1.) restate all of the information  that he had already provided to the Defendant, (2.) provide his full social security number, (3.)  sign a separate "Authorization Release", providing the Defendant with authority to "release a  copy of [his] background check report that [he] had requested."   29.  Plaintiff did not merely request "a copy of his background check report."   30.  Instead, as contemplated by the statute, Plaintiff broadly requested a copy of "all  information that [the Defendant] had about [him], including any information that [it] would sell  to a potential employer that ordered a report using [his] identifying and demographic  information".   32. This intentionally adopted policy and procedure requiring consumers to sign the "Copy Request Form" as a pre-requisite to obtaining the full consumer disclosure that contained  all information about the consumer within the Defendant's possession, together with the sources  of the information and the identity of anyone who had obtained it in the past, as contemplated by  Congress, violated the Fair Credit Reporting Act.   33. Upon information and belief, the Defendant implemented this artificial roadblock in order to reduce the number of disclosures that it would send out, and accordingly, the number  of disputes that it would be required to process, investigate and respond to, in an effort to save  money.    34. The Defendant violated 15 U.S.C. § 1681g by failing to disclose to the Plaintiff all the information contained his consumer file at the time of the request.   35. By requiring the Plaintiff to fill out an additional form, IntelliCorp deprived the Plaintiff of his consumer disclosure and its valuable information despite the requirements of the  FCRA and according to the Defendant’s standard practices and procedures, thereby causing the  Plaintiff to suffer informational injury.     36. The Plaintiff restates each allegation in the preceding paragraphs 1 through 35 as if set forth at length herein.   37. IntelliCorp violated 15 U.S.C. § 1681g(a)(1) by failing to disclose all of the Plaintiff’s information that it maintained at the time of the request.   38. IntelliCorp violated 15 U.S.C. § 1681g(a)(2) by failing to disclose all the sources of the information maintained in the consumer's file at the time of the request.   40.  Pursuant to Rule 23 of the Federal Rules of Civil Procedure, the Plaintiff brings  this action for himself and on behalf of a class defined as follows:  All natural persons residing in the United States (a.) who requested their consumer  disclosure from IntelliCorp; (b.) to whom IntelliCorp responded within the two years  preceding the filing of this action and during its pendency; (c.) to whom IntelliCorp sent a  “Copy Request Form”; and (d.) to whom IntelliCorp did not send a copy of that  consumer's disclosure.  Excluded from the class definition are any employees, officers, or  directors of IntelliCorp, any attorney appearing in this case, and any judge assigned to  hear this action.    41.  The Plaintiff incorporates his prior allegations and estimates that the class is so  numerous that joinder of all members is impractical.  Although the precise number of class  members is known only to the Defendant, Plaintiff's counsel is aware from past litigation that  IntelliCorp is an established business that sends out tens of thousands of consumer file  disclosures each year.   If IntelliCorp uniformly sent its "Copy Request Form" to each such  individual, then the class size is at least that number, and certainly higher if the Court infers that  there are some number of individuals (like the Plaintiff) who ultimately never received their file  disclosure at all.   42.  The Plaintiff’s claim is typical of those of the class members and are all are based  on the same facts and legal theories.    44. Certification of a class under Rule 23(b)(1) of the Federal Rules of Civil Procedure is proper.  Prosecuting separate actions would create a risk of adjudications that would  be dispositive of the interests of the other members not parties to the individual adjudications or  would substantially impair their ability to protect their interests.     45. Certification of a class under Rule 23(b)(2) of the Federal Rules of Civil Procedure is appropriate in that the Defendant acted on grounds generally applicable to the class,  thereby making declaratory relief appropriate with respect to the class as a whole.   47. IntelliCorp violated 15 U.S.C. § 1681g(a)(1) by failing to disclose all of the information maintained in its database at the time of the Plaintiff’s and each putative class  member’s request.   48. IntelliCorp violated 15 U.S.C. § 1681g(a)(2) by failing to disclose all of the sources of the information maintained in its database at the time of the Plaintiff’s and each  putative class member’s request.   49. IntelliCorp violated 15 U.S.C. § 1681g(a)(3) by failing to disclose the identity of each person that procured the information maintained in their database about the consumer at the  time of the Plaintiff’s and each putative class member’s request.   50. The Defendant’s violations were willful, pursuant to 15 U.S.C. § 1681n, or, in the alternative, negligent, entitling the Plaintiff and putative class members to recover under 15  U.S.C. § 1681o.   51. As a result of the Defendant’s violations, the Plaintiff and the putative class members suffered damages including informational injury, the inability to determine the sources  of that information, and the inability to determine the identities of each person that procured their  file.  They are therefore entitled to recover statutory damages, punitive damages and attorneys  fees and costs.  7.  Plaintiff has historically been the victim of inaccurate credit reporting by various  background check agencies.     8.  One of these companies that sells so-called "wholesale" criminal records to a  variety of other smaller background check companies previously sold records regarding the  Plaintiff that falsely indicated that he was a sex offender registered in Virginia, and additionally  that he had also registered as a sex offender in Milwaukee, Wisconsin.     9.  These reportings were both false.    Violation of 15 U.S.C. § 1681g  