24. At no point prior to or after March 4, 2017, did Plaintiff have an account  with Defendant.    25. At no point prior to or after March 4, 2017, did Plaintiff inquire about  Defendant’s services.   26. Nonetheless, on March 4, 2017, Defendant pulled Plaintiff’s Trans Union  credit report without a permissible purpose.   27. Despite the fact that Plaintiff did not have an account with Defendant,  Defendant performed an unauthorized regular or ”hard” credit report inquiry  with Trans Union.   35. Plaintiff brings this action on behalf of himself and on behalf of all others  similarly situated (the “Class”).   48. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   49. The foregoing acts and omissions constitute numerous and multiple violations  of the FCRA.   50. As a result of each and every negligent violation of the FCRA, Plaintiff is  entitled to statutory damages, pursuant to 15 U.S.C. § 1681o(a)(1); and  reasonable attorneys’ fees and costs pursuant to 15 U.S.C. § 1681o(a)(2),  from Defendant.    THE FAIR CREDIT REPORTING ACT  15 U.S.C. §§ 1681-1692X (FCRA)  