21.  Despite the FCRA’s requirements, Equifax regularly declines to block the  reporting of fraudulent information by wrongfully rejecting valid identity theft reports outright  and relying instead on the same verification procedures it uses for common disputes.   22.  In violation of the FCRA, Equifax willfully and negligently fails to provide the  notice required by section 1681c-2(c)(2) after declining to block information that, pursuant to  section 1681c-2(c)(1), a consumer has alleged is the result of identity theft.   23.  In further violation of the FCRA, Equifax willfully and negligently declines to  block the reporting of information alleged by consumers to result from identity theft in  violation of section 1681c-2(a) despite its receipt of all required documentation from the  consumers.   24.  The plain language of section 1681c-2 is clear and Equifax is on notice of its  requirements, both from guidance from the Federal Trade Commission and the prior decision in  Osada, supra.   25.  According to standardized policies and procedures, Equifax willfully treats valid  identity theft claims as regular credit disputes.   45.  Plaintiff realleges and incorporates by reference all preceding paragraphs as  alleged above.    46.  Equifax willfully and negligently failed to comply with section 1681c-2(a) of  the FCRA by failing to block information alleged by consumers to result from identity theft  despite receiving all information required by Section 1681c-2(a).     47.  Plaintiff and Class Members seek actual damages, statutory damages, punitive  damages, attorney fees and costs pursuant to 15 U.S.C. §§ 1681n and o.  48.  Plaintiff realleges and incorporates by reference all preceding paragraphs as  alleged above.   A.  Factual Allegations Regarding Defendant’s Practices   Failure to Provide Required Notice  Violation of Fair Credit Reporting Act, 15 U.S.C. § 1681c-2(c)(2)   Failure to Block Fraudulent Information  Violation of Fair Credit Reporting Act, 15 U.S.C. § 1681c-2(a)  