(15 U.S.C. § 1681e(a):  Class Claim)  169. Plaintiffs reallege Paragraph Nos. 1-162 as if fully set forth herein.  170. The FCRA requires CRAs to “maintain reasonable procedures designed  to avoid violations of section 1681c.”  15 U.S.C. § 1681e(a).    171. Defendant willfully violated Section 1681e(a) of the FCRA by failing  to maintain reasonable procedures to avoid violating Section 1681c.  Indeed,  Defendant’s procedures failed to exclude adverse items of information from its  consumer reports that antedate the consumer report by more than seven years, and  are not records of criminal convictions.  172. Defendant knew or should have known about its obligations under the  FCRA.  These obligations are well established in the plain language of the FCRA,  in the promulgations of the Federal Trade Commission, and in well-established case  law.  173. Defendant obtained or had available substantial written materials that  apprised it of its duties under the FCRA.  174. Despite knowing of these legal obligations, Defendant acted  consciously in breaching its known duties and deprived Plaintiffs and other  similarly-situated individuals of their rights under the FCRA.  41.  Among other things, the FCRA regulates the collection, maintenance,  and disclosure of consumer reports by CRAs, including public record information.   42.  Defendant investigates and reviews public record databases and  maintains consumer files that contain public record information concerning, among  other things, the alleged criminal record history of individuals.   43.  From its files, Defendant sells consumer reports to employers wishing  to investigate the criminal record history, or lack thereof, with regard to job  applicants or current employees.     44.  When a CRA furnishes a copy of a consumer’s report to the consumer  or a third party, the CRA is required to exclude adverse items of information,  including non-conviction criminal records, which antedate the report by more than  seven years.  See 15 U.S.C. § 1681c(a)(5) and Cal. Civ. Code § 1786.18.   45.  Under the FCRA, adverse items of information, such as non-conviction  criminal records, which antedate the consumer report by more than seven years, may  be included in a consumer report, but only for consumer reports used in connection  with the employment of any individual at an annual salary which equal, or which  may be reasonably expected to equal $75,000 or more.  See 15 U.S.C. § 1681c(b)(3).   A.  Checkr’s Practices as a Consumer Reporting Agency and Furnisher of  Consumer Information for Employment Purposes.    i.  Checkr Reports Antiquated Information.   