10.  TransUnion routinely reports information about tax liens on consumer reports and  continues to report tax liens for a specified number of years after they have been paid, satisfied or  released.     11.  On or about May 5, 2016, a Massachusetts state tax lien in the amount of $500 was  entered against the property where Plaintiff lives in Worcester County, Northern District,  Massachusetts.   12.  On or about June 28, 2016, Plaintiff caused payment in full to be sent to the proper  authority, and on July 18, 2016, the lien was released.    14.  The “Status Date” for the lien record listed on the August 2017 report was “06/16,”  which indicates that TransUnion had made no effort to check for updated public records on  Plaintiff for over a year.     15 U.S.C. § 1681e(b)   15.  Despite the satisfaction of the tax lien, as reflected on Massachusetts public records,  and pursuant to its usual and systemic practice, TransUnion did not remove the tax lien public  record from Plaintiff’s credit reports, nor update it to show it as satisfied, released or paid.   16.  Massachusetts maintains online registries per county that are searchable by name  or address.  (See www.masslandrecords.com.)  These records can be searched for free.    17.  Worcester County, Northern District maintains its online searchable records at  www.fitchburgdeeds.com, which is also accessible through the site www.masslandrecords.com,  once “North Worcester” is selected as the County to search.  These records can be searched for  free.    19.  Both from the face of the search results and from the underlying records, it is clear  that Plaintiff’s tax lien has been paid and released.  It is also clear that this release occurred in July  2016.   20.  The FCRA provides: “Whenever 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.”  15 U.S.C. § 1681e(b).   21.  TransUnion is well aware that it has problems with failing to accurately report  public record information.  In fact, it has been sued multiple times for reporting out-of-date tax  lien information in particular.  See Matthews v. Trans Union, LLC, No. 17-cv-01825 (E.D. Penn.);  Dennis v. Trans Union, LLC, No. 14-cv-2865 (E.D. Penn.); Anderson v. Trans Union, LLC, No.  16-cv-558 (W.D. Va.); Clark v. Trans Union, LLC, No. 15-cv-391 (E.D. Va.).  These suits were  filed well in advance of the reporting of Plaintiff’s lien here.     22.  TransUnion receives its public record information that it includes on its reports  from a third party.  TransUnion knows that the tax lien information it obtains from this third party  are often inaccurate, out of date, and/or stale.  Yet, TransUnion does not take any action to ensure  that the information it receives is accurate before reporting it.    24.  These rules were supposed to be in effect as of July 1, 2017, a month prior to  TransUnion’s inaccurate reporting of Plaintiff’s lien status, and a year after the date of the release  of the lien public record.  However, the rules were clearly not in effect, because Plaintiff’s lien  was more than a year out of date, and the face of the report indicated the record had not been  updated since June of 2016.    25.  TransUnion’s failure to accurately report Plaintiff’s tax lien occurred because it  failed to follow reasonable procedures to assure maximum possible accuracy in the preparation of  reports.  Specifically, TransUnion does not obtain up to date information on the status of tax lien  releases, even though such information is freely available online.    26.  Indeed, TransUnion has no systematic procedure to assure that, when tax liens are  paid, satisfied or released, the updated status is promptly obtained and reflected upon a consumer’s  credit report.    27.  Plaintiff incorporates by reference all preceding paragraphs as alleged above.   28.  Plaintiff brings this action pursuant to the Federal Rules of Civil Procedure 23(a)  and 23(b)(3) on behalf of the following Class:  All consumers who: (i) had a tax lien recorded in the State of  Massachusetts; (ii) the tax lien appeared on a TransUnion consumer  report dated within two years prior to the filing of this Complaint and  continuing through the resolution of this case; (iii) the State of  Massachusetts public record indicated that the tax lien had been paid,  satisfied, or released on a date prior to the date of the TransUnion  consumer report, and (iv) the TransUnion consumer report incorrectly  identified the tax lien as not released, unpaid, or with an unpaid balance.   30.  TransUnion likely possesses data for consumers that include name, address, date of  birth, Social Security Number, case numbers/lien identifiers, lien amounts, jurisdiction of liens,  disposition of the liens, date of file in public record, date of disposition in public record, and dates  consumers had credit inquiries where such information was reported.  TransUnion is likely able to  produce this data in standardized spreadsheet form.   31.  Massachusetts, in turn, maintains electronic records of liens, easily accessible and  reviewable, that are searchable by name, and include record descriptions, file dates, disposition  dates, lien identifiers, and other identifying information.    32.  The Massachusetts data can be easily compared to TransUnion’s data to ascertain  which consumers would meet the definition of the Class above.    33.  Existence and Predominance of Common Questions of Law and Fact.  Common  questions of law and fact exist as to all members of the Class, and predominate over the questions  affecting only individual members.  The common legal and factual questions include, among  others:    a.  Whether TransUnion willfully violated the FCRA by reporting tax liens which,  according to Massachusetts public records, were paid; and  b.  Whether TransUnion willfully violated the FCRA by failing to follow reasonable  procedures to assure the maximum possible accuracy of the Massachusetts tax lien  information it reported.    35.  Adequacy.  Plaintiff is an adequate representative of the Class.  Her interests are  aligned with, and are not antagonistic to, the interests of the members of the Class she seeks to  represent.  She has retained counsel competent and experienced in such litigation, and intends to  prosecute this action vigorously.  Plaintiff and her counsel will fairly and adequately protect the  interests of members of the Class.   36.  Predominance and Superiority.  Questions of law and fact common to the class  members predominate over questions affecting only individual class members, and a class action  is superior to other available methods for the fair and efficient adjudication of the controversy.   TransUnion’s conduct described in this Complaint stems from common and uniform practices,  resulting in common violations of the FCRA.  Members of the Class do not have an interest in  pursuing separate actions against TransUnion, as the amount of each class member’s individual  claim is small compared to the expense and burden of individual prosecution.  Class certification  also will obviate the need for unduly duplicative litigation that might result in inconsistent  judgments concerning TransUnion’s practices.  Moreover, management of this action as a class  action will not likely present any difficulties.  In the interests of justice and judicial efficiency, it  would be desirable to concentrate the litigation of all class members’ claims in a single forum.   38.  Plaintiff incorporates by reference all preceding paragraphs as alleged above.   39.  TransUnion failed to comply with 15 U.S.C. § 1681e(b) by failing to follow  reasonable procedures to assure maximum possible accuracy of the tax lien information in the  consumer reports it prepared regarding Plaintiff and the other class members.   40.  The foregoing violations were negligent.        41.  The foregoing violations were willful.     43.  TransUnion’s inaccurate reporting of Plaintiff and class members’ lien information  harmed, and/or created a risk of real harm to, their concrete interests under the FCRA.   7.  TransUnion is one of the “big three” credit reporting agencies in the United States.   8.  TransUnion sells consumer reports (commonly called “credit reports”) about  millions of consumers annually.   9.  TransUnion is regulated by the FCRA.  