11.  In enacting the relevant FCRA provision, Congress unambiguously required  credit-reporting agencies, such as Experian, to "clearly and accurately disclose to the consumer"  who requests his or her credit file "all of the information in the consumer's file at the time of the  request," including the sources of the information. 15 U.S.C. § 168lg(a)(l)-(2).   12.  Disclosure of the source of a consumer-reporting agency's information is vital so  that certain credit reporting errors that originate at the source can be corrected, and so that  consumers always know who is furnishing important credit information about them.   13.  Congress this created a consumer's legal entitlement to material information in  their credit file - the ability to always know what information was to be in their credit report and  who was supplying it.   14.  Despite the clear mandate of § 168lg, Experian willingly bends the rules to  appease some of its customers and to ensure that those customers use Experian' s products, as  opposed to its major competitors Equifax and Trans Union.   15 u.s.c. § 1681i  (INDIVIDUAL CLAIM)   15 U.S.C. § 1681e(b)  (INDIVIDUAL CLAIM)   15.  Experian has substantial notice and knowledge that its policy violates the FCRA,  but Experian knowingly deprives consumers of this important and mandatory FCRA-govemed  information.   17.  In December 2014, granted the plaintiffs motion for summary judgment in  Dreher, fmding Experian willfully violated the FCRA as to the plaintiff and nearly 70,000  consumers. Again, the Court observed: "[a ]!though gifted legal minds can create myriad  interpretations for how many sources or what kinds of sources should be included in the  disclosure, the term 'sources' clearly includes, at the very least, the entity that gives that  information directly to the consumer reporting agency." Dreher v. Experian Info. Sols., Inc., 71  F. Supp. 3d 572, 579-80 (E.D. Va. 2014) (Gibney, J.).   18.  In addition to Dreher, Experian has been sued repeatedly for failing to clearly and  accurately disclose the sources of information it obtains and reports regarding consumers. See,  e.g., Williams v. Experian Info. Solutions, Inc., Case No. 1:13-cv-1102 (E.D. Va.); Beattie v.  Experian Info. Solutions, Inc., Case No. 1:13-cv-1195 (E.D. Va.); Clarkv. Experian Info. Sols.,  Inc., Case No. 3:16-cv-32 (E.D. Va.); Scott v. Experian Info. Sols., Inc., Case No. 3:14-cv-394  (E.D. Va.).   19.  Despite these lawsuits, including a $12 million dollar judgment entered against in  Dreher, Experian has not significantly modified its procedures to clearly and accurately disclose  the sources of information it reports.   20.  In fact, upon information and belief, Experian consciously refuses to even adopt a  written policy for compliance with§ 1681g(a)(2}-a cornerstone provision of the FCRA enacted  more than 40 years ago.   22.  In order to attempt to circumvent state usury, payday lending, and consumer fraud  statutes, John Paul Reddam ("Reddam") created several criminal enterprises, including Delbert  Services Corporation ("Delbert"), CashCall, Inc. ("CashCall") and WS Funding, LLC ("WS  Funding") to market and collect illegal loans.   23.  Reddam's scheme was designed to violate the usury and payday lending laws of  multiple states, to disguise Reddam and his companies' roles, and to ostensibly shield the scheme  from liability through a business structure that attempted to exploit Indian Tribal Sovereign  Immunity to "avoid state and federal law and to game the entire system." Hayes v. Delbert  Servs. Corp., 811F.3d666, 676 (4th Cir. 2016).   24.  Although Western Sky held itself out to consumers as the actual lenders of these  internet payday loans, CashCall funded these illegal loans purportedly made by Western Sky  and, unbeknownst to consumers, was the entity that performed the underwriting requirements.   25.  The companies engaged in this deceptive practice in order to evade liability  because Westerns Sky held itself out to the public as a standalone tribal entity that was  supposedly part of the Cheyenne River Sioux Tribe and, by its assertion, entitled to Native  American Tribal Sovereign Immunity.   26.  Although Western Sky operated within the boundaries of the Cheyenne River  Sioux Reservation, the Sioux Tribe did not have any ownership interest or operating role in  Western Sky, nor did it receive any profits from Western Sky.   28.  Contrary to the misrepresentations in the Loan Agreement, Western Sky was not  an actual lender. As explained by the New Hampshire Department of Banking in 2013, Western  Sky was "nothing more than a front to enable CashCall to evade licensure by state agencies and  to exploit Indian Tribal Sovereign Immunity to shield its deceptive business practices from  prosecution by state and federal regulators."   29.  As explained below, Experian helped facilitate Western Sky and Reddam's  deceptive scheme by: (1) misrepresenting to consumers that it furnished reports directly to  Western Sky when, in reality, Experian furnished those reports directly to CashCall; (2) failing to  disclose CashCall as a source of the information despite Experian's unquestionable knowledge  that it was CashCall who supplied the underlying information to Experian; and (3) by disclosing  "Consumer Loan Trust" as a source of information even though "Consumer Loan Trust" never  furnished any information to Experian.  Experian Misrepresents the Roles of Western Sky, CashCall and Delbert   30.  In order to qualify for the internet payday loan, Western Sky ostensibly required  consumers to electronically sign a loan agreement (the "Loan Agreement").   31.  On November 20, 2012, Mr. White applied for a loan with Western Sky and  electronically signed a template Loan Agreement.   32.  As part of Reddam's deceptive scheme, the Loan Agreement did not reference  CashCall and, more importantly, did not authorize Cashcall to obtain Mr. White's credit report.   33.  After Mr. White submitted his application on November 20, 2012, he received an  e-mail from Western Sky indicating that his application was conditionally approved.   35.  The "Your Credit Score and the Price You Pay for Credit" email was sent by  "do.not.reply@westernsky.com."   36.  On November 29, 2012, Mr. White received another email from Western Sky  entitled "Notice of Assignment, Sale or Transfer of Servicing Rights." This e-mailed explained  "[e]ffective today, your loan is now owned by WS Funding, LLC and will be serviced by a  company called CashCall."   37.  In May 2014, Mr. White requested a full copy of his file from Experian, who  furnished Mr. White with a copy of his consumer disclosure.   38.  In this disclosure, unbeknownst to the Plaintiff at the time, Experian falsely  represented that it furnished Mr. White's credit report to Western Sky on November 20, 2012.   39.  Recently, through discovery produced by Delbert in Hayes v. Delbert Services  Corporation, Case No. 3:14-cv-258 (JAG), Plaintiff discovered that Experian did not, in fact,  provide any report to Western Sky on November 20, 2012.   40.  Instead, Experian provided the November 20, 2012 report to CashCall and  knowingly misrepresented this fact to help facilitate CashCall's efforts to evade licensure and  attempt to exploit Indian Sovereign Immunity.   41.  Experian not only misrepresented that it provided Mr. White's report to Western  Sky, but it also falsely identified "Delbert Services/Consumer Loan Trust" as a source of certain  information in the May 2014 report.   43.  Instead, upon information and belief, CashCall provided Experian with all of the  information appearing in the Delbert Services/Consumer Loan Trust tradeline, yet Experian  concealed this information from consumers.   44.  On October 8, 2014, Mr. White mailed a letter to Experian disputing the  information purportedly reported by "Delbert Services/Consumer Loan Trust." In his letter,  Plaintiff explained that the Defendants' account should be deleted because the loan was null and  void in Virginia. To verify the accuracy of his representations, Plaintiff enclosed regulations  regarding consumer finance licensing in the Commonwealth of Virginia and a recent complaint  against an internet payday lender filed by the Attorney General for the Commonwealth of  Virginia showing that similar loans were considered null and void in Virginia.   45.  Experian conducted its investigation of Mr. White's dispute by secretly contacting  CashCall-not Delbert Services or the Consumer Loan Trust-a clear indication that Experian  knowingly concealed this relevant information from Mr. White.   46.  More specifically, when Experian received a consumer dispute, Experian usually  translates that dispute into an "ACDV" form.   47.  Experian then electronically transmits the ACDV to the source of the information  through a dispute system named "e-Oscar."   48.  As reflected by the ACDV produced involving Delbert, Experian sent the ACDV  to CashCall in response to Mr. White's dispute dated October 8, 2014.   50.  In March 2016, Mr. White requested a full copy of his file from Experian, who  furnished Mr. White with a copy of his consumer disclosure.   51.  Again, this disclosure identified Delbert Services/Consumer Loan Trust as a  source of the information while at the same time concealing CashCall-the entity who gave the  relevant information directly to Experian.   52.  At this time, White discovered that Experian reported information belong to  Plaintiffs father in his credit report, including an American Express card opened in 1967-the  year White was born.   53.  Experian included this information in Plaintiffs credit report due to its lax  threshold designed to over-include information in consumer reports. Accordingly, White alleges  an individual claim against Experian under 15 U.S.C. § 1681e(b) for its failure to reasonably  ensure the maximum possible accuracy of his credit reports.   54.  Likewise, Mr. Hayes requested a full copy of his file from Experian, who  furnished Mr. Hayes with a copy of his consumer disclosure dated April 2, 2016. Again, this  disclosure identified Delbert Services/Consumer Loan Trust as a source of the information while  at the same time concealing CashCall-the entity who gave the relevant information directly to  Experian.   56.  Experian not only deprived Plaintiffs of important information, but Experian also  subject Plaintiffs and the class members to increased risk of harm, including the increased risk  that Plaintiffs and the class members would continue to pay amounts on these unlawful loans.  Experian's conduct also made it more difficult for Plaintiffs and the class members to get these  illegal loans removed from their credit reports.   57.  Further, the value of the incomplete or partial credit disclosure Experian provided  was thus less in some amount than the $12.00 price the FCRA sets as the cost of such disclosure.  58.  Plaintiffs restate each of the allegations in the preceding paragraphs as if set forth  at length herein.   59.  Pursuant to Rule 23 of the Federal Rules of Civil Procedure, Plaintiffs bring this  action for themselves and on behalf of a class defined as follows:  All natural persons residing in the United States (including all territories  and other political subdivisions of the United States) (a) who requested  their consumer file from Experian or any of its affiliated companies,  subsidiaries, or any other Experian entity, (b) within five years preceding  the filing of this action and during its pendency, and ( c) to whom Experian  provided a response that included a Delbert Services and/or Consumer  Loan Trust tradeline. Excluded from the class definition are any  employees, officers, directors of Experian, any attorney appearing in this  case, and any judge assigned to hear this action.   60.  Upon information and belief, Plaintiffs' counsel estimates that the class is so  numerous that joinder of all members is impractical.   62.  Plaintiffs' claims are typical of those of the class members. All are based on the  same facts and legal theories. Experian's response to a consumer's request for a full copy of his  or her consumer file routinely failed to disclose Cash Call as the source of the information during  the full class period. The violation alleged is the same and the class claim will rise and fall  entirely based upon whether or not Plaintiffs' claiin rises or falls.   63.  The Plaintiffs will fairly and adequately protect the interests of the class. The  Plaintiffs have retained counsel experienced in handling actions involving unlawful practices  against consumers and class actions. Neither Plaintiffs nor their counsel have any interests that  might cause them not to vigorously pursue this action. The Plaintiffs are aware of their  responsibilities to the putative classes and have accepted such responsibilities.   64.  Certification of a class under Rule 23(b)(l) of the Federal Rules of Civil  Procedure is proper. Prosecuting separate actions by or against individual class members would  create a risk of adjudications with respect to individual class members that, as a practical matter,  would be dispositive of the interests of the other members not parties to the individual  adjudications or would substantially impair or impede their ability to protect their interests.   66.  Certification of the class under Rule 23(b)(3) of the Federal Rules of Civil  Procedure is also appropriate in that:  a.  As alleged above, the questions of law or fact common to the members of the  classes predominate over any questions affecting an individual member. Each of the common  facts and legal questions in the case overwhelm the more modest individual damages issues.  Further, those individual issues that do exist can be effectively streamlined and resolved in a  manner that minimizes the individual complexities and differences in proof in the case.  b.  A class action is superior to other available methods for the fair and efficient  adjudication of the controversy. Consumer claims generally are ideal for class treatment as they  involve many, if not most, consumers who are otherwise disempowered and unable to afford and  bring such claims individually. Further, most consumers affected by Experian's FCRA violation  would likely be unaware of their rights under the law, or who they could find to represent them  in federal litigation. Additionally, individual litigation of the uniform issues in this case would  be a waste of judicial resources. The issues at the core of this case are class wide and should be  resolved at one time. One win for one consumer would set the law as for every similarly situated  consumer.   67.  Experian violated § 1681g(a)(2) of the FCRA by: (1) failing to clearly and  accurately disclose CashCall as the source of the information reported in the Delbert  Services/Consumer Loan Trust tradeline; and/or (2) by misrepresenting that Consumer Loan  Trust was a source of the information even though Consumer Loan Trust did not exist and never  provided any information to Experian.   69.  Experian is permitted to charge up to $12.00 for a consumer disclosure.  However,  it  m  fact  uses  its  confusing  website  and  marketing  campru.gn  ("FreeCreditReport.Com") to direct consumers to a product for which it charges at least $21.95  per month. In fact, it does this to direct consumers away from the one actually free option they  have - AnnualCreditReport.com.   70.  Nevertheless, whether a plaintiff or putative class member managed to obtain  their one free annual credit disclosure or instead paid for it, the value of that report is still set at  $12.00.   71.  Because the consumer disclosures Experian provided did not include all of the  information Experian was obligated to include in them, they were worth some amount less.   72.  Additionally, by example only and without imitations, the rights at issue were  determined by Congress to be important measures of Experian' s process to ensure continued  accuracy and completeness in its files and reports.   73.  The conduct, action, and inaction of Experian was willful, rendering Experian  liable for statutory and punitive damages in an amount to be determined by the Court pursuant to  15 U.S.C. § 1681n. In the alternative, the violation was negligent entitling class members to the  $12.00 value of a complete credit disclosure.   75.  As a result of these FCRA violations, Experian is liable to the Plaintiffs and to  each putative class member for statutory damages from $100.00 to $1,000.00, punitive damages,  and/or actual damages in the amount of $12.00, as well as for their attorney's fees and costs  pursuant to 15 U.S.C. § 1681n.  76.  Plaintiffs restate each of the allegations in the preceding paragraphs as if set forth  at length herein.   77.  Pursuant to Rule 23 of the Federal Rules of Civil Procedure, Mr. White bring this  action for himself and on behalf of a class defmed as follows:  All natural persons residing in the United States (including all territories  and other political subdivisions of the United States) (a) who requested  their consumer file from Experian or any of its affiliated companies,  subsidiaries, or any other Experian entity, (b) within five years preceding  the filing of this action and during its pendency, and ( c) to whom Experian  provided a response that included an inquiry from Western Sky. Excluded  from the class definition are any employees, officers, directors of  Experian, any attorney appearing in this case, and any judge assigned to  hear this action.  Mr. White is a member of this class.   78.  Upon information and belief, Plaintiffs' counsel estimates that the class is so  numerous that joinder of all members is impractical.   80.  Plaintiffs' claims are typical of those of the class members. All are based on the  same facts and legal theories. Experian's response to a consumer's request for a full copy of his  or her consumer file routinely failed to include the source of the public records information that  it reported about consumers during the full class period. The violation alleged is the same and the  class claim will rise and fall entirely based upon whether or not Plaintiffs' claim rises or falls.   81.  The Plaintiffs will fairly and adequately protect the interests of the class. The  Plaintiffs have retained counsel experienced in handling actions involving unlawful practices  against consumers and class actions. Neither Plaintiffs nor their counsel have any interests that  might cause them not to vigorously pursue this action. The Plaintiffs are aware of their  responsibilities to the putative classes and have accepted such responsibilities.   83.  Certification of a class under Rule 23(b)(2) of the Federal Rules of Civil  Procedure is appropriate in that Experian has acted on grounds generally applicable to the class  thereby making appropriate declaratory relief with respect to the class as a whole.   84.  Certification of the class under Rule 23(b)(3) of the Federal Rules of Civil  Procedure is also appropriate in that:  a.  As alleged above, the questions of law or fact common to the members of the  classes predominate over any questions affecting an individual member. Each of the common  facts and legal questions in the case overwhelm the more modest individual damages issues.  Further, those individual issues that do exist can be effectively streamlined and resolved in a  manner that minimizes the individual complexities and differences in proof in the case.  b.  A class action is superior to other available methods for the fair and efficient  adjudication of the controversy. Consumer claims generally are ideal for class treatment as they  involve many, if not most, consumers who are otherwise disempowered and unable to afford and  bring such claims individually. Further, most consumers affected by Experian's FCRA violation  would likely be unaware of their rights under the law, or who they could find to represent them  in federal litigation. Additionally, individual litigation of the uniform issues in this case would  be a waste of judicial resources. The issues at the core of this case are class wide and should be  resolved at one time. One win for one consumer would set the law as for every similarly situated  consumer.   86.  Each Plaintiff and putative class member suffered real and actual injury. They  were denied important information that was to have been part of their consumer disclosure  otherwise to be provided upon request.   87.  Experian is permitted to charge up to $12.00 for a consumer disclosure.  However,  it  m  fact  uses  its  confusing  website  and  marketing  campaign  ("FreeCreditReport.Com") to direct consumers to a product for which it charges at least $21.95  per month. In fact, it does this to direct consumers away from the one actually free option they  have - AnnualCreditReport.com.   88.  Nevertheless, whether a plaintiff or putative class member managed to obtain  their one free annual credit disclosure or instead paid for it, the value of that report is still set at  $12.00.   89.  Because the consumer disclosures Experian provided did not include all of the  information Experian was obligated to include in them, they were worth some amount less.   90.  Additionally, by example only and without imitations, the rights at issue were  determined by Congress to be important measures of Experian's process to ensure continued  accuracy and completeness in its files and reports.   91.  The conduct, action, and inaction of Experian was willful, rendering Experian  liable for statutory and punitive damages in an amount to be determined by the Court pursuant to  15 U.S.C. § 168ln. In the alternative, the violation was negligent entitling class members to the  $12.00 value of a complete credit disclosure.   93.  As a result of these FCRA violations, Experian is liable to the Plaintiffs and to  each putative class member for statutory damages from $100.00 to $1,000.00, punitive damages,  and/or actual damages in the amount of $12.00, as well as for their attorney's fees and costs  pursuantto 15 U.S.C. § 168ln.  94.  Mr. White incorporates all other factual allegations set forth in the Complaint.   95.  Experian violated multiple sections of§ 1681i as to Mr. White, including but not  limited to its conduct of: (1) failing to conduct a reasonable reinvestigation to determine whether  the disputed information was inaccurate and record the current status of the disputed information  or delete the item from Plaintiffs credit file in violation of§ 168li(a)(l); (2) failing to review  and consider all relevant information submitted by Mr. White in violation of §1681i(a)(4); (3)  failing to promptly delete the disputed inaccurate items of information from Mr. White's credit  files or modify the item of information upon a lawful reinvestigation of§ 168li(a)(5)(A); and (4)  failing to promptly delete the disputed inaccurate items of information from Mr. White's credit  files or modify the item of information upon a lawful reinvestigation in violation of  §168li(a)(5)(A).   97.  The violations by Experian were willful, rendering it liable for punitive damages  in an amount to be determined by the Court pursuant to§ 1681n. In the alternative, Experian was  negligent, which entitles Plaintiffs to recovery under 15 U.S.C. §16810.   98.  Mr. White is entitled to recover actual damages, statutory damages, costs and  attorney's fees from Experian in an amount to be determined by the Court pursuant to 15 U.S.C.  § 1681n and §16810.  Statutory Framework and Experian 's Recidivist Conduct   Violation of 15 U.S.C. § 1681g(a)(2)  (EXPERIAN)   Violation of 15 U.S.C. §§ 168lg(a)(l) and 1681g(a)(3)  (EXPERIAN)  