11.  The FCRA is intended “to protect consumers from the transmission of inaccurate  information about them, and to establish credit reporting practices that utilize accurate, relevant,  and current information in a confidential and responsible manner.” Cortez v. Trans Union, LLC,  617 F.3d 688, 706 (3d Cir. 2010).   12.  The FCRA requires that consumer reporting agencies (“CRAs”) “follow reasonable  procedures to assure maximum possible accuracy of the information concerning the individual  about whom the report relates.” 15 U.S.C. § 1681e(b).   13.  The maximum possible accuracy standard “requires more than merely allowing for  the possibility of accuracy,” meaning that CRAs do not meet that standard by suggesting that  certain consumers are “possible” matches for individuals on the OFAC List. Ramirez v. Trans  Union, LLC, No.12-cv-00632-JSC, 2017 WL 1133161, *5 (N.D. Cal. Mar. 27, 2017) (quoting  Cortez, 617 F.3d at 709) (emphasis added).   14.  In 2010 in Cortez, the U.S. Court of Appeals for the Third Circuit found that OFAC  information is subject to the maximum possible accuracy standard, and that a CRA acted  “reprehensibly” and was in willful violation of FCRA section 1681e(b) by using only first and last  names to associate consumers with criminals on the OFAC List. 617 F.3d at 707-08, 723.    15 U.S.C. § 1681e(b)   15.  Later, a court in the Northern District of California certified the FCRA section  1681e(b) claims of a class of 8,192 individuals who a CRA inaccurately associated with the OFAC  List. Ramirez, 301 F.R.D. at 413. A jury found that the CRA’s matching procedures willfully  violated the FCRA. Ramirez v. Trans Union, LLC, No. 3:12-cv-632-JSC, 2017 WL 5153280, at  *2-3 (N.D. Cal. Nov. 7, 2017) (upholding jury’s verdict).   17.  Defendant is a CRA within the meaning of FCRA section 1681a(f), in that, for  monetary fees, dues, or on a cooperative nonprofit basis, it regularly engages in the practice of  assembling or evaluating consumer credit information or other information on consumers for the  purpose of furnishing consumer reports to third parties, while using means of interstate commerce,  specifically the U.S. mail and internet, for the purpose of preparing or furnishing consumer reports.    18.  Defendant regularly compiles information bearing on consumers’ creditworthiness,  including credit tradelines and public records, and includes this information on reports for the  purposes of evaluating consumers’ eligibility for credit.   19.  MicroBilt is well aware of the implications of noncompliance with federal  regulations pertaining to doing business with individuals on the OFAC List and markets itself as a  reliable way for businesses to “find out fast” whether their customers are “on the OFAC  watchlist.”3   20.  MicroBilt fails to follow reasonable procedures to assure the maximum possible  accuracy of the OFAC information it sells about consumers, regularly selling reports to prospective  creditors that inaccurately label innocent consumers as criminals on the OFAC List.   21.  MicroBilt’s practices for including references to OFAC information on the  consumer reports it sells are uniform and not unique to each consumer or transaction.   23.  Defendant does this because it wants to provide some OFAC-related information to  its customers (accurate or not), to maximize its profits and advertise that its products “work.”    24.  Defendant thus intentionally employs procedures that maximize the likelihood of a  match between data on the OFAC List and consumers, thereby compromising accuracy.   25.  Defendant’s treatment of OFAC information is not accidental, but instead a result  of deliberately designed policies and procedures.   26.  At all relevant times, Defendant’s conduct, as well as that of 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 Defendant, was intentional, willful, reckless, and in  grossly negligent disregard for the rights of consumers, including Plaintiff.  D.  The Experience Of Plaintiff Maria Hernandez   27.  On or about November 9, 2020, Plaintiff applied for a loan through Oasis1  Marketing, and provided her full name, date of birth, address, and social security number on the  application.   28.  Oasis1 Marketing requested a consumer report about Plaintiff from MicroBilt in  connection with her application and provided Plaintiff’s full personal identifying information to  MicroBilt.   29.  On November 9, 2020, MicroBilt prepared and sold to Oasis1 Marketing a  consumer report about Plaintiff.   30.  MicroBilt included on the first page of the report, in red typeface, “Matches found”  for the “OFAC WatchList.”    31.  MicroBilt did not include on the report any additional information about the  allegedly matching OFAC record(s).   33.  Plaintiff’s year of birth is 1989. Other than sharing the same common first and last  names, she does not share any other identifying information with the individuals listed on the  OFAC List.   34.  Plaintiff is not on the OFAC List or any other government watch list.   35.  Despite having been provided with Plaintiff’s full name, address, social security  number and date of birth, MicroBilt used a loose name matching procedure to determine whether  to include OFAC information on the consumer report, and disregarded available date of birth  information that disqualified any match.   36.  Plaintiff’s loan application was denied based upon the OFAC information on the  MicroBilt report. A representative of Oasis1 Marketing wrote to Plaintiff as follows:  “Unfortunately, your Line of Credit request has been denied because the Instant Bank Verification  process that you completed has come back with a flag that you are on the Federal Government  OFAC Watch List. For more information, you can contact MicroBilt, the company that supports  the Instant Bank Verification process. Their customer service phone number is 800-884-4747.”    37.  As a result of MicroBilt’s inaccurate reporting of the OFAC information, Plaintiff  was denied credit and sustained other damages including harm to reputation and emotional distress.   V.  39.  Plaintiff reserves the right to amend the definition of the Class based on discovery  or legal developments.   40.  Numerosity. Fed. R. Civ. P. 23(a)(1). The members of the Class are so numerous  that joinder of all is impractical. Upon information and belief, the number of consumers harmed  by Defendant’s practices are more numerous than what could be addressed by joinder, and those  persons’ names and addresses are identifiable through documents or other information maintained  by Defendant.    41.  Existence and Predominance of 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 individuals. The common legal and factual questions  include, among others, whether MicroBilt maintains reasonable procedures to assure maximum  possible accuracy of the OFAC information on its consumer reports.   42.  Typicality. Fed. R. Civ. P. 23(a)(3). Plaintiff’s claims are typical of each Class  member. Plaintiff has the same claims for relief that she seeks for absent Class members.   43.  Adequacy. Fed. R. Civ. P. 23(a)(4). Plaintiff is an adequate representative of the  Class because her interests are aligned with, and are not antagonistic to, the interests of the  members of the Class she seeks to represent, she has retained counsel competent and experienced  in such litigation, and she intends to prosecute this action vigorously. Plaintiff and her counsel will  fairly and adequately protect the interests of members of the Class.    45.  Plaintiff incorporates the foregoing paragraphs as though the same were set forth  at length here.   46.  Pursuant to sections 1681n and 1681o of the FCRA, Defendant is liable for  negligently and willfully failing to follow reasonable procedures to assure maximum possible  accuracy of the consumer reports it sold, in violation of 15 U.S.C. § 1681e(b).   6.  The United States Treasury Department’s Office of Foreign Assets Control  (“OFAC”) “administers and enforces economic trade sanctions based on U.S. foreign policy and  national security goals against threats to national security, foreign policy or economy of the United  States.” Ramirez v. Trans Union, LLC, 301 F.R.D. 408, 413 (N.D. Cal. 2014) (citation omitted).1    7.  OFAC directs those sanctions at, among others, terrorists, international narcotics  traffickers, and persons involved in the proliferation of weapons of mass destruction and publishes  a list of those “Specially Designated Nationals” (“SDNs”) and “Blocked Persons” on its website  (the “OFAC List”).2    8.  Persons on the OFAC List are legally ineligible for credit in the United States, may  not be employed, and may even be subject to deportation or criminal prosecution.   9.  The full OFAC List as maintained by the Treasury Department is publicly available  information, and whether a person is on the OFAC List is a matter of public record.   A.  The United States Treasury Department’s Office Of Foreign Assets Control And Its  List Of Specially Designated Nationals And Blocked Persons  