19.   Plaintiff alleges that Equifax is familiar with credit reporting industry  standards and subscribes thereto.   20.   Plaintiff alleges that Equifax understands that deviation from credit reporting  industry standards can and often does result in denial of credit, higher interest  rates, and prompts those making credit decisions to draw a more negative  inference from the reported data than if Equifax reported in accordance with  the recognized industry standard.   21.   Plaintiff alleges that all actions alleged herein by Equifax was done  knowingly, intentionally, and in reckless disregard for credit reporting  industry standards in an attempt to purposefully undermine Plaintiff’s ability  to reorganize and repair Plaintiff’s FICO Score.   22.   In the alternative, Plaintiff alleges that Equifax’s actions were the result of  reckless policies and procedures that inevitably led to inaccurate, misleading,  or incomplete credit reporting.   a.   FICO   23.   FICO Inc. (“FICO”) is a leading analytics software company with its principal  headquarters located in San Jose California. FICO has over 130 patents related  to their analytics and decision management technology, and regularly uses  mathematical algorithms to predict consumer behavior including credit risk.     24.   The FICO Score has become the standard measure of consumer credit risk in  the United States and is used in ninety percent of lending decisions.    25.   A FICO score consists of a three-digit number summarizing a consumer’s  credit risk or likelihood to repay a loan. FICO periodically updates its scoring  models resulting in multiple FICO Score versions.    94.   At all times relevant to this matter, Plaintiff was an individual residing within  the State of California.   95.   Furthermore, Equifax conducted business within the State of California at all  times relevant.   96.   On or about April 24, 2013, Plaintiff filed for a no asset Chapter 7 bankruptcy  in the U.S. Bankruptcy Court for the Eastern District of California in Fresno.  Plaintiff’s case was assigned Case Number 13-bk-25655 (the “Bankruptcy”).5   97.   The obligations (“Debt”) to Wells Fargo for a consumer credit card were  scheduled in the Bankruptcy.   98.   Wells Fargo did not have their Debt ordered to be “non dischargeable”  pursuant to 11 U.S.C. § 523 et seq.   