10.  Prior to October 4, 2019, Plaintiff had an account with Defendant and/or Indiana  University Hospital.   11.  On October 4, 2019, Plaintiff filed a Chapter 7 bankruptcy petition (hereinafter, the  “Bankruptcy Petition”) in the United States Bankruptcy Court for the Southern District of Indiana  (hereinafter, the “Bankruptcy Court”), commencing bankruptcy case number 19-07435-RLM-7.   12.  At the time Plaintiff filed her Bankruptcy Petition, she owed a debt to Indiana  University Hospital (hereinafter, “the Debt”).   13.  The Debt was assigned to and/or purchased by Defendant for collection from  Plaintiff.   15.  Plaintiff scheduled the Debt in her Bankruptcy Petition.   16.  At the time Plaintiff filed her bankruptcy petition, she owed no other debt to  Defendant.   17.  At the time Plaintiff filed her bankruptcy petition, she had no other accounts with  Defendant.   18.  On or about January 14, 2020, the Bankruptcy Court entered an order discharging  Plaintiff’s debts, thereby extinguishing her liability for the Debt (hereinafter, “the Discharge  Order”).   19.  When the Bankruptcy Court entered the Discharge Order, the debtor-creditor  relationship ended between Plaintiff and Defendant as to the Debt    20.  Moreover, at the time of Plaintiff’s discharge, there were no assets in the  bankruptcy estate from which to make any distribution to Plaintiff’s potential creditors.   21.  Given that Plaintiff’s bankruptcy discharge resulted in a Report of No Distribution  (i.e., Plaintiff had no assets in her estate to distribute to any creditors), any unsecured debts that  were incurred prior to the filing of Plaintiff’s bankruptcy petition are considered discharged,  irrespective of whether the debt was specifically listed in Plaintiff’s schedule of creditors, filed as  part of her Bankruptcy Petition.     22.  The Debt, and any other account(s) Plaintiff had with Defendant, or that had been  assigned to Defendant, and that had been incurred prior to the date Plaintiff filed her Bankruptcy  Petition, were effectively discharged as of the date of the Discharge Order.   24.  As of January 16, 2020, Defendant was effectively put on notice that any debt  incurred prior to the filing of Plaintiff’s Bankruptcy Petition was discharged.   25.  Defendant was aware that any debt incurred by Plaintiff prior to October 4, 2019,  which was assigned to Defendant for collection, was discharged in bankruptcy.   26.  At no time since January 14, 2020 has Plaintiff owed any debt to Defendant.   27.  At no time since January 14, 2020 has Plaintiff opened any accounts with  Defendant.   28.  At no time since January 14, 2020 has Plaintiff had any personal business  relationship with Defendant.   29.  Given the facts delineated above, at no time since January 14, 2020 has Defendant  had any information in its possession to suggest that Plaintiff owed a debt to Defendant.    30.  Given the facts delineated above, at no time since January 14, 2020 has Defendant  had any information in its possession to suggest that Plaintiff was responsible to pay a debt to  Defendant.    31.  Experian Information Solutions, Inc., (hereinafter, “Experian”) is a consumer  reporting agency as that term is defined by 15 U.S.C. § 1681a(f).  Experian is a data repository  that assembles and stores information on consumers for the purpose of furnishing consumer reports  to third parties.   33.  Given the overwhelming scope of the information available when one procures a  consumer report about another, in 1970 Congress enacted the FCRA to protect consumer privacy  by requiring consumer reporting agencies to, inter alia, limit the furnishing of consumer reports  to statutorily enumerated purposes only.  See TRW Inc., v. Andrews, 534 U.S. 19, 23 (2001).     34.  The statute was created in response to “concerns about corporations’ increasingly  sophisticated use of consumers’ personal information in making credit and other decisions.”  Syed  v. M-I, LLC et al., 846 F.3d 1034, 1037 (9th Cir. 2017) (citing the FCRA, Pub.L. 91-508, Section  602, 84 Stat. 1114, 1128).  See also,  United States v. Bormes, 568 U.S. 6, 7 (2012) (The Fair  Credit Reporting Act has as one of its purposes to “protect consumer privacy” (quotation and  citation omitted)); Cole v. U.S. Capital, 389 F.3d 719, 723 (7th Cir. 2004) (“In [§1681] Congress  made it clear that the FCRA is designed to preserve the consumer's privacy in the information  maintained by consumer reporting agencies.”).   35.  When it enacted the FCRA, Congress found, among other things, that “[t]here is a  need to insure that consumer reporting agencies exercise their grave responsibilities with fairness,  impartiality, and a respect for the consumer's right to privacy.”  15 U.S.C. § 1681(a)(4).     36.  Tasked with protecting a consumer’s privacy, the FCRA governs who can access  consumer report information from credit reporting agencies and for what purpose.  To that end,  the FCRA enumerates certain “permissible purposes” for accessing credit reports.   38.  Defendant also furnishes data to Experian about its experiences with its customers  and potential customers.     39.  Defendant is a “furnisher” of information as contemplated by  the FCRA, 15 U.S.C.  § 1681s-2(a) & (b), that regularly and in the ordinary course of its business furnishes information  to one or more consumer reporting agency about its transactions and/or other experiences with  consumers.   40.  Defendant has a symbiotic relationship with Experian such that it furnishes  information to Experian regarding its transactions and/or other experiences with consumers while  also purchasing from Experian information about its customers and other consumers.   41.  On or about January 28, 2020, despite being cognizant of the facts as delineated  above, Defendant procured from Experian a copy of Plaintiff’s consumer report at which time,  Defendant made a general or specific certification to Experian that Defendant sought the consumer  report in connection with a business transaction initiated by Plaintiff, to review an account to  determine whether Plaintiff continued to meet the terms of said account, or for some other  permissible purpose enumerated by the FCRA.   42.  The certification made by Defendant to Experian was false.     43.  Despite certifying to Experian that it had a permissible purpose for procuring  Plaintiff’s consumer report, Defendant had no such permissible purpose.   44.  At no time on or prior to January 28, 2020 did Plaintiff consent to Defendant  obtaining her consumer report.   46.  On or about January 28, 2020, at the time Defendant impermissibly procured from  Experian Plaintiff’s individual and personal credit report, Plaintiff’s Confidential Information was  published to Defendant.    47.  On or about January 28, 2020, at the time Defendant impermissibly procured from  Experian Plaintiff’s individual and personal credit report, Defendant reviewed Plaintiff’s  Confidential Information.    48.  On or about January 28, 2020, at the time Defendant impermissibly procured from  Experian Plaintiff’s individual and personal credit report, unknown employees, representative  and/or agents of Defendant viewed Plaintiff’s Confidential Information.   49.  On or about January 28, 2020, at the time Defendant impermissibly procured from  Experian Plaintiff’s individual and personal credit report, Defendant obtained information relative  to Plaintiff’s credit history and credit worthiness.   50.  Plaintiff has a right to have her Confidential Information kept private.   51.  No individual/entity is permitted to obtain and review Plaintiff’s personal and  confidential information unless either Plaintiff provides her consent for the release of the  information or the individual/entity has a permissible purpose to obtain the confidential  information as enumerated by the FCRA.   52.  Defendant procured from Experian Plaintiff’s consumer report without her  knowledge or consent.   53.  Defendant procured from Experian Plaintiff’s consumer report without a  permissible purpose.   55.  By its actions, when Defendant impermissibly procured from Experian Plaintiff’s  individual and personal credit report, Defendant effectively intruded upon the seclusion of  Plaintiff’s private affairs.   56.  When Plaintiff discovered that Defendant had procured her personal, private and  confidential information from Experian, Plaintiff was extremely angry, frustrated and suffered  emotional distress resulting from Defendant’s invasion of her privacy.     57.  When Plaintiff discovered that Defendant had procured her personal, private and  confidential information from Experian, Plaintiff was extremely worried, concerned and frustrated  that Defendant’s impermissible access of her personal, private and confidential information from  one or more consumer reporting agency could continue indefinitely.   58.  When Plaintiff discovered that Defendant had procured her Confidential  Information from Experian, Plaintiff was concerned about the continued security and privacy of  her Confidential Information.   59.  When Plaintiff received her Discharge Order from the Bankruptcy Court, she  rightfully believed that her business relationship with Defendant had come to an end.  When  Plaintiff discovered that Defendant had procured her Confidential Information after it had been  sent notice of Plaintiff’s bankruptcy discharge, Plaintiff believed that Defendant would continue  to act with impunity and continue to procure her Confidential Information indefinitely.   61.  Plaintiff brings this action pursuant to the Federal Rules of Civil Procedure 23(a)  and 23(b)(3) on behalf of the following class of individuals:   All persons about whom, during the two (2) year period prior to the filing  of the Complaint in this matter, Defendant obtained a consumer report  pertaining to a consumer after that consumer had obtained a bankruptcy  discharge of any debt said consumer owed to Defendant and/or any debt  that was being collected from Plaintiff by Defendant, and for any secured  debts, after said consumer had been dispossessed of any property securing  such a debt (hereinafter, the “Class”).   62.  Plaintiff reserves the right to amend the definition of the Class based on discovery  or legal developments.   63.  Numerosity.  Fed. R. Civ. P. 23(a)(1).  The Class members are so numerous that  joinder of all is impractical. Defendant sells thousands of consumer reports on consumers each  year, and those persons’ names and addresses are identifiable through documents maintained by  Defendant.   64.  Common Questions of Law and Fact.  Fed. R. Civ. P. 23(a)(2).  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: (i) Whether Defendant violated section 1681b(f) of the FCRA by procuring Plaintiff’s  consumer report without a permissible purpose.   65.  Typicality.  Fed. R. Civ. P. 23(a)(3).  Plaintiff’s claims are typical of the claims  of each Class member, which all arise from the same operative facts and are based on the same  legal theories.   67.  Predominance and Superiority.  Fed. R. Civ. P. 23(b)(3).  Questions of law and  fact common to the Class members predominate over questions affecting only individual members,  and a class action is superior to other available methods for fair and efficient adjudication of the  controversy.  The statutory and punitive damages sought by each member are such that individual  prosecution would prove burdensome and expensive given the complex and extensive litigation  necessitated by Defendant’s conduct.  It would be virtually impossible for the members of the  Class individually to redress effectively the wrongs done to them.  Even if the members of the  Class themselves could afford such individual litigation, it would be an unnecessary burden on the  courts.  Furthermore, individualized litigation presents a potential for inconsistent or contradictory  judgments and increases the delay and expense to all parties and to the court system presented by  the complex legal and factual issues raised by Defendant’s conduct.  By contrast, the class action  device will result in substantial benefits to the litigants and the Court by allowing the Court to  resolve numerous individual claims based upon a single set of proof in a unified proceeding.    VI.  68.  Plaintiff incorporates the foregoing paragraphs as though the same were set forth at  length herein.   9.  As alleged in this pleading, “credit reports” are “consumer reports” as that term is  defined by 15 U.S.C. §1681a(d).   On behalf of Plaintiff and the Class  