10.  After approximately 90 days of placement with Yanfeng Automotive, Defendant  informed Plaintiff that Yanfeng intended to proceed with hiring Plaintiff on a full time basis.   11.  As part of its employment application process, Defendant requires full time  employees such as Plaintiff to submit to a background check wherein information pertaining to  character, general reputation, personal characteristics and/or mode of living are reviewed and  used to determine, together with other factors, whether to hire an applicant.   12.  In or around June 2017, Defendant advised Plaintiff it would be performing a  background check on Plaintiff.   14.  Said consumer report was to be used by Defendant to assist in determining  Plaintiff’s fitness for the full time position, and to assist in determining whether to continue to  hire Plaintiff for a position of employment.   15.  After receiving and reviewing the consumer report obtained regarding Plaintiff,  Defendant intended to deny Plaintiff the employment opportunity based in whole or in part on  the aforesaid consumer report.    16.  On or about June 28, 2017, Defendant made a determination not to hire Plaintiff.    17.  At no time after making the determination not to hire Plaintiff did Defendant  provide any oral, written, or electronic notice to Plaintiff of the name, address and telephone  number of the consumer reporting agency that furnished the consumer report to Defendant that  was used in whole or in part to deny Plaintiff employment.   18.  At no time after making the determination not to hire Plaintiff did Defendant  provide Plaintiff oral, written, or electronic notice of the Plaintiff’s right to obtain a free copy of  the report on Plaintiff from the consumer reporting agency that furnished the consumer report to  Defendant that was used in whole or in part to deny Plaintiff employment.   19.  Prior to taking any action on Plaintiff’s employment application to deny Plaintiff  the employment opportunity, Defendant failed to provide Plaintiff a copy of the consumer report  to Plaintiff.    20.  Prior to taking any action on Plaintiff’s employment application to deny Plaintiff  the employment opportunity, Defendant failed to provide to Plaintiff a description in writing of  the rights of Plaintiff under the FCRA.    22.  As a result of Defendant’s conduct, as delineated above, Plaintiff has suffered  actual damages in the form of financial and dignitary harm arising from the Defendant’s review  of his personal information and an injury to his reputation, and Defendant’s failure to provide  Plaintiff the requisite disclosures and an opportunity to spare his good name and obtain  meaningful employment.  Furthermore, Plaintiff will continue to suffer the same harm for an  indefinite time in the future, all to Plaintiff’s great detriment and loss.   23.  In conducting a background check and obtaining a consumer report on Plaintiff  for purposes of employment, Defendant violated the FCRA in one or more of the following  ways:  a. Failed to provide the Plaintiff with a copy of the report procured for employment  purposes prior to taking any adverse action against the Plaintiff in violation of 15  U.S.C. §1681b(b)(3)(A)(i);  b. Failed to provide the Plaintiff, prior to taking any adverse action against the Plaintiff,  with a description in writing of the rights of Plaintiff under the Fair Credit Reporting  Act  in violation of 15 U.S.C. §1681b(b)(3)(A)(ii);  c. Otherwise negligently and willfully violated the Fair Credit Reporting Act.   V.  24.   Plaintiff brings this action individually and on behalf of a class of individuals  pursuant to Rule 23 of the Federal Rules of Civil Procedure.   26.  The class is so numerous that joinder of all members is impractical.  Upon  information and belief, Defendant has used consumer reports in order to screen hundreds,  possibly thousands, of potential employees.     27.  There are questions of law and fact common the Class that predominate over any  questions affecting only individual Class members.  The principal question at issue is whether  Defendant violated the FCRA by failing to provide proper pre-adverse action notice, to Class  members during the applicable time period as alleged.   28.  Plaintiff’s claim is typical of the claims for the Class, which arise from the same  operative facts and are predicated on the same legal theories.   29.  There are no individual questions of fact, other than whether a Class member did  not receive pre-adverse action notice, which can be determined by a ministerial inspection of  Defendant’s records.   30.  Plaintiff will fairly and adequately protect the interests of the Class.  Plaintiff is  committed to vigorously prosecuting this matter and has retained counsel experience in handling  class actions and claims involving unlawful business practices.  Neither Plaintiff nor counsel for  Plaintiff have any interests that might cause them to not vigorously pursue this claim.   32.  A class action is a superior method for the fair and efficient adjudication of this  controversy.  The identities of individual Class members may be easily obtained from  Defendant’s records.  VI.  8.  Defendant is a recruitment agency, providing recruitment services for its clients  by seeking candidates for temporary and full time employment.   9.  In or around March 2017, Plaintiff was employed by Defendant and placed with  Yanfeng Automotive.  