27.   By contrast, a request for information from the PSP database costs $10.00.   Moreover, if the person’s record shows arrests or convictions, there will not be a response for at  least two to three weeks, and often longer.  For these reasons, CRAs seldom order or wait for  PSP records before generating a background check, unless the job for which a person is being  screened requires a PSP record check as a matter of law.   28.  AOPC also provides for bulk purchases of its criminal record information.  CRAs  as a matter of general practice use the AOPC database as their public source of criminal history  data in Pennsylvania.   29.  As a general practice, expunged criminal charges in Philadelphia are hidden from  public view in AOPC’s database within days of an expungement order.  They are completely  eliminated from the database that is provided to bulk purchasers shortly thereafter.   31.  As of the removal from public view of the expunged charges from AOPC’s  database, any preparer of a background check that maintained strict procedures designed to  insure complete and up to date information would have been aware that it was no longer  appropriate to report the expunged charges.   32.  Even if a preparer were to rely instead on bulk data obtained from AOPC, the  preparer would know that expunged charges had been eliminated if it properly updated its  database.   33.  Defendant reported the expunged charges on Mr. Giddiens’ background check  report more than a year and a half after they had been hidden from public view and then  eliminated from AOPC’s database.   34.  Defendant failed to search for updated public record information on Mr.  Giddiens’ expunged criminal charges, because the only source of information that it could have  obtained in the time frame in which it produced and sold the report to Infinity was the AOPC  database, from which the charges had long been hidden from public view and removed by the  time that the report was compiled.   35.  In preparing a report on Mr. Giddiens in December 2011, Defendant did not  search any public records in which Mr. Giddiens’ charges had not yet been expunged.  Mr.  Giddiens’ charges had been eliminated from all public records by that time.   36.  Defendant’s background report prepared in December 2011 lists the source of the  expunged case as “Court of Common Pleas” even though the case had been eliminated from  AOPC’s database before the report was compiled because of the Expungement Order.   38.  After retaining counsel, Mr. Giddiens disputed the accuracy of the background  report to Defendant.   39.  After receiving his dispute Defendant allegedly performed a reinvestigation of the  information he disputed, and reported on the results of the reinvestigation in a letter dated  February 20, 2012.   40.  The letter violated the requirements of section 1681i(a)(6) in a number of ways,  including the following: the letter did not include a consumer report that is based on the  consumer’s file as that file is revised as a result of the reinvestigation; the letter did not include a  notice that, if requested by the consumer, a description of the procedure used to determine the  accuracy and completeness of the information shall be provided to the consumer; the letter did  not include a notice that the consumer has the right to add a statement to the consumer’s file  disputing the accuracy or completeness of the information; and, the letter did not include a notice  that the consumer has the right to request that the consumer reporting agency furnish notification  that the item has been deleted to any person designated by the consumer who has within two  years prior thereto received a consumer report for employment purposes, or within six months  prior thereto received a consumer report for any other purpose, which contained the deleted or  disputed information.  A copy of the letter is attached hereto as Exhibit A.   42.  At all times pertinent hereto, Defendant was acting by and through its agents,  servants and/or employees who were acting within the course and scope of their agency or  employment, and under the direct supervision and control of the Defendant herein.   43.   At all times pertinent hereto, the conduct of the Defendant, as well as that of its  agents, servants and/or employees, was intentional, willful, reckless, and in grossly negligent  disregard for federal laws and the rights of the Plaintiff herein.  Defendant knowingly carries out  a business practice of reporting criminal record information that is not current or up to date, and  without assuring that such information has not been expunged and/or had its status changed.   There is no reading or interpretation of section 1681e(b) of the FCRA, or any provision for that  matter, which would justify, sanction, excuse or condone such a practice.     51.  Plaintiff incorporates the foregoing paragraphs as though the same were set forth  at length herein.   52.  Pursuant to sections 1681n and 1681o, Defendant is liable for negligently and  willfully violating the FCRA by failing to follow reasonable procedures to assure maximum  possible accuracy of the information concerning the individual about whom a consumer report  relates, in violation of section 1681e(b).   54.    Pursuant to section 1681n and 1681o of the FCRA, Defendant is liable for  negligently and willfully violating the FCRA by sending notices of the results of reinvestigations  that do not comply with the requirements of section 1681i(a)(6)(B).  55.  Pursuant to section 1681n and 1681o of the FCRA, Defendant is liable for  negligently and willfully violating section 1681k of the FCRA by failing to notify Plaintiff of the  fact that it furnished public record information about him to Infinity, along with Infinity’s name  and address, at the time it furnished such information.   