14.  Plaintiff Brian Miller is a resident of the State of Arizona, who after serving time in  prison, complied with all aspects of the law, and after repaying his debt to society, had his  convictions set aside and expunged from his record in accordance with the laws of the State of  Arizona, with the most recent order being issued in 2015. Under the laws of the State of Arizona,  all rights he had before his troubles with the law have been restored to him, and he carries forward  no disabilities from his prior troubles with the law.  3  36.  Plaintiff brings this action on behalf of himself and all other persons similarly  situated pursuant to Rule 23(a) and (b)(3) of the Federal Rules of Civil Procedure.   37.  Plaintiff is a member of and seeks to certify his claims alleged in his First Claim for  Relief on behalf of a class defined as follows:  All natural persons with an address in the United States and its Territories about  whom, beginning two years prior to the filing of this Complaint and continuing  8  50.  Plaintiff alleges and incorporates by this reference the allegations in all preceding  paragraphs.   51.  Plaintiff, the Expungement Class Members, and the Administrative Action Class  Members are “consumers,” as defined by the FCRA, 15 U.S.C. § 1681a(c).   52.  At all times pertinent hereto, Defendants RealPage, Inc., and RP On-Site, LLC, are  and were defined as  a “person” and “consumer reporting agency” (CRA) as those terms are defined  by 15 U.S.C. §§ 1681a(b) and (f).   53.  15 U.S.C. § 1681e(b), requires that a consumer reporting agency, “shall follow  reasonable procedures to assure maximum possible accuracy of the information concerning the  individual about whom the report relates.”   54.  As alleged herein, Defendants violated 1681e(b) in its consumer reports issued to  its customers by reporting convictions which had been expunged, sealed, or otherwise removed  from public dissemination.   55.  Also as alleged herein, Defendants violated 1681e(b) by reporting administrative  actions by departments of corrections as “felony convictions,” when in fact, such administrative  actions were never adjudicated in any Court.   56.  The foregoing violations were willful. Defendants acted in deliberate or reckless  disregard of its obligations and the rights of Plaintiff, the Expungement Class Members and the  Administrative Action Class Members under 15 U.S.C. § 1681e(b). In fact, Defendants have been  12  60.  Plaintiff hereby incorporates by this reference each and every preceding paragraph  of this Complaint as if fully set forth herein.   61.  In return for money, Defendants furnished consumer reports on Plaintiff and other  Antedated Report Class members, to third-parties for tenant screening purposes.   62.  The consumer reports issued by Defendants to its customers included (1) civil suits,  civil judgments, and records of arrest that, from date of entry, antedate the report by more than  seven years or until the governing statute of limitations has expired, whichever is the longer period;  and/or (2) any other adverse item of information, other than records of convictions of crimes, which  antedates the report by more than seven years.  13  For Violation of the Federal Credit Reporting Act  (Violation of 15 U.S.C. § 1681e(b) and 15 U.S.C. § 1681m)  (On Behalf of Plaintiff, the Expungement Class, and the Administrative Action Class  against All Defendants)   For Violation of the Federal Credit Reporting Act  Reporting Antedated Charges  (Violation of 15 U.S.C. § 1681c(a)(2) and (5))  (On Behalf of the Plaintiff and the Antedated Report Class against all Defendants)  