10. Mr. Cole’s financial woes caused him to fall behind and default on some of his  debts and obligations, including a credit card account with Chase Bank (USA), N.A. (“Chase”)  and a medical debt to Norton Hospitals, Inc. (“Norton”).    11. Chase charged off Mr. Cole’s account and assigned it to First Resolution  Investment Corp. (“First Resolution”), who sued him on September 25, 2014 to collect the debt.   -3-  12. First Resolution later moved for and was granted a default judgment against Mr.  Cole, which was entered of record on November 13, 2014.    13. Norton sued Mr. Cole on August 21, 2014 in order to collect the Norton debt.  14. Norton later moved for and was granted a default judgment against Mr. Cole,  which was entered of record on December 31, 2014.   15. Mr. Cole paid off the First Resolution and Norton default judgments in full.   16. Norton filed a notice of satisfaction of record in the Norton case on June 23, 2015.  17. First Resolution filed a notice of satisfaction of record in the First Resolution case  on September 15, 2016.   18. The filed notices of satisfaction in the First Resolution and Norton cases are  public records that are freely and readily available to all.    19. On September 26, 2016, Mr. Cole obtained copies of his consumer credit report  from Defendant, Experian Information Solutions, Inc. (“Experian”).   20. Mr. Cole’s September 26th consumer credit report from Experian inaccurately  stated, in the section of the report devoted to information concerning public records, that both the  First Resolution and Norton judgments remained unpaid and unsatisfied with positive amounts  still due and owing.   21. Mr. Cole was denied credit and financing because of inaccurate credit information  published by Experian in connection with the First Resolution and Norton judgments. In  particular, Experian falsely and incorrectly published to one or more of its subscribers and users  of its consumer reports that the First Resolution and Norton judgments were not satisfied and  that a positive balance was still owed on each of the judgments.   22.   Experian’s reporting of the First Resolution and Norton judgments as unsatisfied  was inaccurate in violation of the FCRA, 15 U.S.C. § 1681e(b). Experian failed to follow  reasonable procedures to assure maximum possible accuracy in the preparation of Mr. Cole’s  credit reports and credit files each publishes and maintains concerning Mr. Cole. If Experian had  reasonable procedures in place, Experian each would have discovered that First Resolution and  Norton had filed a notice of satisfaction before publishing Mr. Cole’s credit report to its  subscribers and users of each’s consumer reports in connection with Mr. Cole’s loan and credit  applications.   23. Experian failed to maintain reasonable procedures designed to avoid violations of  the FCRA in connection with publishing credit information concerning Mr. Cole and the  satisfied First Resolution and Norton judgments.   -4- II. Further Factual Allegations   24. As a pattern and practice, Experian falsely and incorrectly published information  to its subscribers and users of its consumer reports that judgments against numerous Kentucky  consumers which had been satisfied or vacated were not satisfied and that a positive balance was  still owed on each of the judgments.   25. As a pattern and practice, Experian failed to maintain reasonable procedures  designed to avoid violations of the FCRA in connection with publishing credit information  concerning satisfied or vacated judgments against numerous Kentucky consumers.   26. As a pattern and practice, Experian has failed to follow reasonable procedures to  assure maximum possible accuracy in the preparation of credit reports and credit files it  publishes regarding numerous Kentucky consumers. 27. Plaintiff Christopher Cole (“Cole”) brings this action individually and as a class  action on behalf of all persons in the Commonwealth of Kentucky similarly situated comprised  of the following persons:  CLASS: All Kentucky consumers regarding whom Defendant, Experian Information  Solutions, Inc. (“Experian”), has, within two (2) years of the filing of the present  complaint, falsely and incorrectly published information to its subscribers and users of its  consumer reports that a judgment against the consumer that was satisfied, vacated, or  non-final at the time Experian published the information remained unsatisfied, final,  and/or with an outstanding balance due and owing.   28. This action seeks actual damages and maximum statutory damages for Experian  Information Solutions, Inc.’s violations of the FCRA for all members of the proposed classes; for  injunctive relief against Experian Information Solutions, Inc. enjoining it from further violation  of such federal law; for punitive damages pursuant to 15 U.S.C. § 1681n for Experian’s willful  conduct as alleged supra; and for an award of attorneys’ fees and allowable court costs.   29. The proposed Class as set out supra and so represented by Plaintiff Christopher  Cole in this action, and of which he himself is a member, consists of those persons defined above  which are so numerous that joinder of individual members is impracticable.   30. Plaintiff’s claims are typical of the claims of the proposed Class as set out supra.  31. There are common questions of law and fact applicable to the members of the  proposed Class in this action that relate to and affect the rights of each member of the proposed  classes, and the relief sought is common to the entire proposed class. In particular, all members  of the proposed Class have the same issues of law and fact in common: -5- (a) Whether Experian had a duty of maximum possible accuracy pursuant to 15 U.S.C. §  1681e(b) with regard to the public records information it collected and published  regarding Mr. Cole and members of the Class, and whether its conduct satisfied said  duty under the FCRA;  (b) Whether Experian maintained reasonable procedures designed to avoid violations of  the FCRA in connection with publishing public records information concerning Mr.  Cole and members of the Class.   32. There is no known conflict between Plaintiff and any other members of the  proposed Class with respect to this action, or with respect to the claims for relief herein set forth.   33. Plaintiff is the representative party for the proposed Class and is able to, and will,  fairly and adequately protect the interest of the proposed Class.   34. Plaintiff’s attorneys are experienced and capable in the field of consumer rights,  including FDCPA violations.   35. Plaintiff’s attorneys have successfully represented other claimants in similar  litigation.   36. The action is properly maintained as a class action in that the prosecution of  separate actions by individual class members of the proposed Class creates a risk of individual  adjudications that would, as a practical matter, be dispositive of the interests of the other  members not parties to the adjudication, or would substantially impair or impede their ability to  protect their interest.   37. This action is properly maintained as a class action because the prosecution of  separate actions by individual members of the proposed Class would create risk of varying  individual adjudications, which would establish incompatible standards of conduct for  Defendant.  38. This action is properly maintained as a class action inasmuch as the questions of  law and fact common to the proposed class members predominate over any questions affecting  only individual members; a class action is superior to other methods available for the efficient  adjudication of the controversy; the relief sought by all members of the proposed Class will be  effective and appropriate for the entirety of each proposed class; and all members of the  proposed Class have a right to damages or other relief that may be readily computed in each case  or otherwise readily determined.   39. The identity of each individual member of the proposed Class can be ascertained  from the books and records maintained by Defendant.   40. Because many of the persons who comprise the proposed Class in this case may  not be aware of their rights, or may not be in a financial position to readily assert their rights, and because relegation of their claims to individual actions would result in an unreasonable  -6- multiplicity of suits and a corresponding burden on this and other courts, a class action is far  superior to all other methods for a fair and efficient adjudication of this controversy.  9. As a result of the great economic recession of 2008, Mr. Cole suffered economic  harm and loss through no fault of his own.    I. Facts as to Christopher Cole  