20.  Plaintiff Ashlyn Meeks sued Trans Union and settled with Trans Union. On or  about November 20, 2019, Ms. Meeks attempted to access her credit file disclosure through the  www.annualcreditreport.com website. The website did not return a credit file disclosure, but  rather the following message: “Unfortunately, your request cannot be fulfilled online at this time,  based upon the data provided.”   22.   Plaintiff Kenneth Mahl had a similar experience. Mr. Mahl sued Trans Union,  settled his case, and now can’t access his credit file at www.annualcreditreport.com. Trans  Union’s attorney has confirmed in an email that “when a consumer files a lawsuit against Trans  Union, the file is locked for a period of generally about 3 years to prevent mishandling and to  ensure only Trans Union operators can provide the report. Until that period is up, Mr. Mahl will  not be able to use sites like the one below to view his report.” The reference to “sites like the one  below” refers to www.annualcreditreport.com.   34.  Plaintiffs seek to certify a class of those natural persons, who, in the last 5 years  has had their access to their credit file disclosure via www.annualcreditreport.com blocked by  Trans Union after the person sued Trans Union.    35.  The identities of all class members are readily ascertainable from the records of  Trans Union.    38.  Based on discovery and further investigation Plaintiffs may, in addition to moving  for class certification using modified definitions of the class, class claims, and the class period,  and/or seek class certification only as to issues as permitted under Fed. R. Civ. P. 23(c)(4). Such  modified definitions may be more expansive to include consumers excluded from the foregoing  definitions. 