1. whether Defendant Monica Braverman obtained, re-disclosed, and/or resold  Plaintiff and Class Member's personal information contained within motor vehicle  records maintained by the State motor vehicle departments;    1. Lane v. Facebook, Inc., 696 F.3d 811, 821 (9thCir. 2012) cert. denied,13-136, 2013  WL 5878083(U.S. Nov. 4, 2013), a Federal Class Action, decided by the United States  Supreme Court, involving similar underlying facts as the present action, about 30  companies, violations of the Video Privacy Protection Act ("VPPA"), 18 U.S.C. §  2710, et seq.;   2. Cross v. Blank, Adv. No.: 9:15ap00926FMD, (M.D. Fla. 2015), a Federal Class  Action involving similar underlying facts as the present action, violations of the  Driver's Privacy Protection Act ("DPPA"),18 U.S.C. § 2721, et seq.;   10. Sharon Taylor et. al. v. Safeway Inc. et. al., 2:07-cv-0017, (E.D. Tex. 2007), a  Federal Class Action involving similar underlying facts as the present action, about  50 companies, violations of the Driver's Privacy Protection Act ("DPPA"), 18 U.S.C. §  2721, et seq.;     10. whether Defendant BB Direct Inc. obtained the written express consent of  Plaintiff and Class Members to obtain, re-disclose, and/or resell Plaintiff and Class  Member's personal information contained within motor vehicle records maintained  by the State motor vehicle departments;   11. whether Defendant TaCito & Associates obtained the written express consent of  Plaintiff and Class Members to obtain, re-disclose, and/or resell Plaintiff and Class  Member's personal information contained within motor vehicle records maintained  by the State motor vehicle departments;   11. Sharon Taylor et. al. v. Biometric Access Company et. al., 2:07-cv-0018, (E.D.  Tex. 2007), a Federal Class Action involving similar underlying facts as the present  action, about 50 companies, violations of the Driver's Privacy Protection Act  ("DPPA"), 18 U.S.C. § 2721, et seq.;     12. Sharon Taylor et. al. v. Freeman Publishers Inc., 2:07-cv-0410, et. al., (E.D. Tex.  2007), a Federal Class Action involving similar underlying facts as the present action,  about 50 companies, violations of the Driver's Privacy Protection Act ("DPPA"), 18  U.S.C. § 2721, et seq.;   12. whether Defendant Don Herring Ltd. obtained the written express consent of  Plaintiff and Class Members to obtain, re-disclose, and/or resell Plaintiff and Class  Member's personal information contained within motor vehicle records maintained  by the State motor vehicle departments;   13. whether Defendant Monica Braverman acted knowingly when it obtained, re- disclosed, and/or resold Plaintiff and Class Member's personal information contained  within motor vehicle records maintained by the State motor vehicle departments;   14. whether Defendant BB Direct Inc. acted knowingly when it obtained, re-disclosed,  and/or resold Plaintiff and Class Member's personal information contained within  motor vehicle records maintained by the State motor vehicle departments;   15. whether Defendant TaCito & Associates acted knowingly when it obtained, re- disclosed, and/or resold Plaintiff and Class Member's personal information contained  within motor vehicle records maintained by the State motor vehicle departments;   16. whether Defendant Don Herring Ltd. acted knowingly when it obtained, re- disclosed, and/or resold Plaintiff and Class Member's personal information contained  within motor vehicle records maintained by the State motor vehicle departments;   17. whether Defendant Monica Braverman’s conduct described herein violates the  Driver's Privacy Protection Act, 18 U.S.C. §2721;   19. whether Defendant TaCito & Associates Inc.'s conduct described herein violates  the Driver's Privacy Protection Act, 18 U.S.C. §2721;   2. whether Defendant BB Direct Inc.  obtained, re-disclosed, and/or resold Plaintiff  and Class Member's personal information contained within motor vehicle records  maintained by the State motor vehicle departments;    20. whether Defendant Don Herring Ltd.’s  conduct described herein violates the  Driver's Privacy Protection Act, 18 U.S.C. §2721;   21. whether Defendant Monica Braverman, as custodian of the Plaintiff and Class  Members' motor vehicle records, possessed a duty to use reasonable care to  investigate and determine the validity of the claimed DPPA permissible uses by   Defendants BB Direct Inc., TaCito & Associates Inc., and Don Herring Ltd., prior to,  during, and after, re-disclosing, and/or re-selling Plaintiff and Class Members' motor  vehicle records to such entities by permitting procurement, re-disclosure, and re-sale  of the Plaintiff and Class Members' motor vehicle records by such entities, and if so,  whether Defendants Monica Braverman intentionally, or in the alternative,  negligently failed in his obligation;   22. whether Defendant BB Direct Inc., as recipient of the Plaintiff and Class Members'  motor vehicle records from Defendants Monica Braverman had a duty to use  reasonable care to investigate and determine the validity of the claimed DPPA  permissible uses by Defendant Monica Braverman used to obtain, directly or  indirectly, the motor vehicle records from the State Department of Motor Vehicles,  prior to, during, and after, obtaining Plaintiff and Class Members' motor vehicle  records; moreover, whether Defendant BB Direct Inc. , by re-disclosing and re-selling  the Plaintiff and Class Members' motor vehicle records to Defendants had a duty to  use reasonable care to investigate and determine the validity of the claimed DPPA  permissible uses by Defendants, and if so, whether Defendant BB Direct Inc.  intentionally, or in the alternative, negligently failed in his obligation;   23. whether Defendant Tacito & Associates Inc., as recipient of the Plaintiff and Class  Members' motor vehicle records from Defendant BB Direct Inc., had a duty to use  reasonable care to investigate and determine the validity of the claimed DPPA  permissible uses by Defendant BB Direct Inc., used to obtain, directly or indirectly,   the motor vehicle records from the State Department of Motor Vehicles, prior to,  during, and after, obtaining Plaintiff and Class Members' motor vehicle records;  moreover, whether Defendant Tacito & Associates Inc., by re-disclosing and re-selling  the Plaintiff and Class Members' motor vehicle records to Defendants had a duty to  use reasonable care to investigate and determine the validity of the claimed DPPA  permissible uses by Defendants, and if so, whether Defendant Tacito & Associates  Inc., intentionally, or in the alternative, negligently failed in his obligation;   25. whether Defendant Monica Braverman complied with 18 U.S.C.  §2721 (c), the  obligation to maintain a record of any person and/or company that Defendant  Monica Braverman re-disclosed, and /or resold Plaintiff and Class Member's personal  information contained within motor vehicle records maintained by the State motor  vehicle departments for a period of five (5) years; and if so, whether Defendant  Monica Braverman intentionally, or in the alternative, negligently failed in his  obligation;   26. whether Defendant BB Direct Inc.  complied with 18 U.S.C.  §2721 (c), the  obligation to maintain a record of any person and/or company that Defendant BB  Direct Inc.  re-disclosed, and /or resold Plaintiff and Class Member's personal  information contained within motor vehicle records maintained by the State motor  vehicle departments for a period of five (5) years; and if so, whether Defendant BB  Direct Inc., intentionally, or in the alternative, negligently failed in his obligation;   27. whether Defendant TaCito & Associates Inc., complied with 18 U.S.C.  §2721 (c),  the obligation to maintain a record of any person and/or company that Defendant BB  Direct Inc.  re-disclosed, and /or resold Plaintiff and Class Member's personal  information contained within motor vehicle records maintained by the State motor  vehicle departments for a period of five (5) years; and if so, whether Defendant  TaCito & Associates Inc., intentionally, or in the alternative, negligently failed in his  obligation;   28. whether Defendant Don Herring Ltd. complied with 18 U.S.C.  §2721 (c), the  obligation to maintain a record of any person and/or company that Defendant BB  Direct Inc.  re-disclosed, and /or resold Plaintiff and Class Member's personal  information contained within motor vehicle records maintained by the State motor  vehicle departments for a period of five (5) years; and if so, whether Defendant Don  Herring Inc., intentionally, or in the alternative, negligently failed in his obligation;  the nature, and extent of Plaintiff and Class Members' damages;   29. the nature, and extent of all statutory penalties, including liquidated damages of  $2500.00, and/ or damages for which Defendant Monica Braverman are liable for,  and legally obligated to, Plaintiff and Class Members;    3. whether Defendant TaCito & Associates Inc. obtained, re-disclosed, and/or resold  Plaintiff and Class Member's personal information contained within motor vehicle  records maintained by the State motor vehicle departments;   3. Cook v. ACS State & Local Solutions, Inc. 663 F.3d 989 (10th Cir. 2011), a Federal  Class Action involving similar underlying facts as the present actions violations of  the Driver's Privacy Protection Act ("DPPA"), 18 U.S.C. § 2721, et seq.;   31. the nature, and extent of all statutory penalties, including liquidated damages of  $2500.00, and/ or damages for which Defendant TaCito & Associates Inc. is liable for,  and legally obligated to, Plaintiff and Class Members;   31. whether Plaintiff and Class Members are entitled to appropriate injunctive relief  against Defendant BB Direct Inc.;    32. the nature, and extent of all statutory penalties, including liquidated damages of  $2500.00, and/ or damages for which Defendant Don Herring Ltd. is liable for, and  legally obligated to, Plaintiff and Class Members;   32. whether Plaintiff and Class Members are entitled to appropriate injunctive relief  against Defendant TaCito & Associates Inc.;   33. whether Plaintiff and Class Members are entitled to appropriate injunctive relief  against Defendant Don Herring Ltd.; and   33. whether Plaintiff and Class Members are entitled to appropriate injunctive relief  against Defendant Monica Braverman;   34. whether punitive damages are appropriate.  148. The questions of law and fact common to Class Members predominate over any  questions affecting only individual members; and a class action is superior to all other  available methods for the fair and efficient adjudication of his controversy.   4. Doe et. al. v. Compact Information Systems Inc. et al., 3:13cv05013MBH, (N.D.  Tex. 2013), a Federal Class Action involving similar underlying facts as the present  action, violations of the Driver's Privacy Protection Act ("DPPA"), 18 U.S.C. § 2721,  et seq.;   4. whether Defendant Don Herring Ltd. obtained, re-disclosed, and/or resold Plaintiff  and Class Member's personal information contained within motor vehicle records  maintained by the State motor vehicle departments;   5. whether Defendant Monica Braverman had a DPPA permissible use to obtain, re- disclose, and/or resell Plaintiff and Class Member's personal information contained  within motor vehicle records maintained by the State motor vehicle departments;    55. The protections afforded consumers by the Driver’s Privacy Protection Act is premised  upon a screening process qualifying access to state motor vehicle records. This  obligation is imposed on any and all individuals and entities that obtain, re-disclose,  and resell such data, imposing a duty on “Authorized Recipients”, acting as re-sellers  to exercise reasonable care in responding to requests to purchase the motor vehicle  records. Individuals and entities that obtain, re-disclose, and/or re-sell the motor  vehicle records obtained from state motor vehicle departments, must follow screening  policies and reasonable verification measures. Defendants intentionally, or in the  alternative, negligently re-disclosed and/or re-sold motor vehicle records obtained  from the State Department of Motor Vehicles to Defendant National Affiliates,  without adequate screening precautions.    57. On information and belief, the most prevalent unauthorized use of Motor Vehicles  Records obtained from State Department of Motor Vehicles is by those persons  and/or entities involved in the Motor Vehicle Industry, a billion-dollar enterprise. In  order to outline the Defendant’s business practices, and the incentive for Defendants  to act as a “Supplier” or “Distributor”, an understanding of the “Direct Marketing  Vehicle Industry” is necessary, including knowing the participants, the participants’  functions, and entities knowingly funding this enterprise.     59. The Direct Marketing Vehicle Industry employs financial instruments to “vertically  integrate” an association of entities requiring a “lead supply chain”. A state’s MVR  database provides the most accurate and updated database of all licensed drivers and  vehicles, providing a marketing database surpassing all other sources., albeit, the  “Holy Grail” of all databases. As such, the Direct Marketing Vehicle Industry is involved  with any and all means possible, at any costs, ignoring legal constraints, to procure  this database. Once the database is obtained then the marketing and solicitation  scheme can be implemented.    60. Defendant Braverman is an individual involved in the Direct Marketing Industry,  acting as a Direct Market Provider assisting Direct Marketing entities. On information  and belief, Defendant Monica Braverman obtains state motor vehicle records, directly  or indirectly, from many state DMVs.    6. Richard Fresco v. R.L. Polk., No. 09-13344 (11th Cir. 2010), (Fresco II"- Intervention), a Federal Class Action involving similar underlying facts as the  present action, violations of the Driver's Privacy Protection Act ("DPPA"), 18 U.S.C. §  2721, et seq.;   6. whether Defendant BB Direct Inc.  had a DPPA permissible use to obtain, re- disclose, and/or resell Plaintiff and Class Member's personal information contained  within motor vehicle records maintained by the State motor vehicle departments;   61. Defendant BB Direct is a corporation involved in the Direct Marketing Industry, acting  as a Direct Market Provider assisting Direct Marketing persons and entities. Defendant  BB Direct Inc.  obtains state motor vehicle records, directly or indirectly, from many  state DMVs.   62. Defendant TaCito is a corporation involved in the Direct Marketing Industry, acting as  a Direct Market Provider assisting Direct Marketing persons and entities. Defendant  TaCito obtains state motor vehicle records, directly or indirectly, from many state  DMVs.   64. The VSC Industry is the poster child for marketing abuses, illegal telemarketing,  and deceptive mailers. It is a complex financial infrastructure, funded by a  multitude of financial institutions. The core of this industry is “fueled” by illegally  obtaining millions of motor vehicle records from State Motor Vehicle  Departments, the “grease” to create and send the Direct Marketing Vehicle  Industry marketing letters.  C. Defendants’ Business Association & Practices-Admissions Against Interest    66.  Defendant Don Herring Ltd., d/b/a Don Herring Mitsubishi, is an automobile  dealership located in the Dallas/Fort Worth Metroplex area, and describes its  business  as follows:   "We have been in business since 1979, and we have never rested on our  accomplishments. We have since expanded into three dealerships in Dallas,  Irving, and Plano, Texas all serving fine Mitsubishi products"  “Mitsubishi dealership in Texas”, last Accessed September 3, 2016), online:   http://www.donherring.com/about-don-herring-in-tx   67.  After receipt of the Don Herring solicitation letter, Plaintiff Lopez became  concerned about whether his Personal Identifying Information, (“Pii”), and motor  vehicle information, was being sold to marketing companies, jeopardizing his privacy  and security interests, and that of his family, due in part because Plaintiff Lopez did not  have a prior commercial relationship with Defendant Don Herring. Within a few days  after receipt of the letter Plaintiff Lopez contacted Defendant Don Herring’s Dallas office  and spoke to Cary Wilson, a Senior Sales Associate at Don Herring’s office located at  3520 S. Marvin D. Love Freeway, Dallas, Texas. Mr. Wilson informed Plaintiff Lopez that  the source of his vehicle information originated from the Texas State Department of  Motor Vehicles., (See Exhibit 2,“Lopez Dec”).    69. Mr. Reuben Mosely, General Sales Manager at Don Herring’s office located at 3520  S. Marvin D. Love Freeway, Dallas, Texas responded to the inquiry on behalf of Mr.  Wilson and noted, “Yes that is correct. We use a third party company that supplies the  information and it is gathered through vehicle registrations, (See Exhibit 4).    7. Sharon Taylor et al. v. Acxiom Corporation et al., 2:07-cv-0001, (E.D. Tex. 2007), a  Federal Class Action involving similar underlying facts as the present action, about  50 companies, violations of the Driver's Privacy Protection Act ("DPPA"), 18 U.S.C. §  2721, et seq.;   70. In review of the Defendant Don Herring’s solicitation letter a company was noted in  fine print at the bottom of one (1) of the pages. It was TaCito & Associates Marketing,  reportedly, “a direct marketing advertising agency that specializes in automotive  marketing”, TaCito & Associates Marketing is a subsidiary of Defendant TaCito &  Associates, Inc., and owned by Anthony J. TaCito. Defendant Tacito’s involvement was  further noted in this letter by its offering of additional benefits if Plaintiff Lopez accessed  the following website online: arthurlopez.KEYFORKEYEVENTS.COM, and entered the  activation code: TDM 1456. This website is owned by TaCito & Associates Marketing.   Reportedly TaCito & Associates Marketing has in excess of 167 similar domains used for  direct marketing, including but not limited to, cdjrtestdrive.com,  chevyupgradeevents.com, lhmprovoupgradeevents.com, dhmitsugc.com,  bobboyteupgradeevents.com, ramgift.com, getsmorevalue.com, dhgiftcard.com,  dealergc.com, vipappt.com, and vtgiftcard.com.   72. On May 14, 2016 an inquiry was sent to Mr. Anthony J. TaCito, CEO of Defendant  TaCito & Associates Inc., requesting information as to the source of the vehicle  information displayed on Plaintiff Lopez’s solicitation letter sent by Defendant  Don Herring, sources identified by Mr. Wilson and Mr. Mosely as Defendant  TaCito & Associates Inc.. Mr. TaCito responded on May 16, 2016 stating the  data was supplied by Defendant BB Direct Inc. for the past 13 years, (See  Exhibit 5).    73. The document attached to Mr. TaCito’s May 16, 2016 response, referenced as  “ArthurlopezRecord (1). Xlsx 9K”, was noted as “a copy of the records provided  from the BBDirect data file”. (See Exhibit 6).    74. In review of this “ArthurlopezRecord” document, a column referenced as  “Odometer”, noted an odometer reading of “15”. The exact odometer reading is  legally required to be provided to State Department of Motor Vehicles when  motor vehicles are purchased. A document obtained from the Texas Department  of Motor Vehicles when Plaintiff Lopez purchased his motor vehicle reveals the  identical odometer reading of “15” as shown in the “ArthurlopezRecord”  document possessed by Defendant TaCito & Associates Inc., and Defendant BB  Direct Inc., (See Exhibit 7).   76. On May 17, 2016 an inquiry was sent to Mr. Brian Berg, CEO of Defendant BB  Direct Inc., requesting information as to the source of the information displayed  on Plaintiff Lopez’s solicitation letter sent by Defendant Don Herring, a source  identified by Mr. A. J. TaCito of Defendant TaCito & Associates Inc., as originating  from Defendant BB Direct Inc. Mr. Berg confirmed that Defendant BB Direct Inc.  had been hired by Defendant TaCito & Associates Inc. to handle the account of  this dealership, Defendant Don Herring Ltd., and Mr Berg stated the data had  been supplied by Defendant Braverman. (See Exhibit 9).    77. Defendant BB Direct Inc. is reportedly a ”provider of direct marketing data and  data related services”, marketing automobile mailing lists:         “BB Direct Inc. ’s Premium Automobile Mailing List is the most up-to-date and  robust auto database of its kind, outperforming other similar lists in terms of  accuracy and coverage. In addition to selecting by make, model, and year, BB  Direct Inc. ’s automobile database also includes VIN (Vehicle Identification  Number) information. Unlike some automobile files, our database has coverage  in all 50 states, is Shelby compliant, and is updated every 2 weeks.”  “Automobile Mailing List”, last Accessed September 3, 2016), online:   http://www.bbdirect.com/auto- dealership-data/automobile-mailing-list   79. On May 17, 2016 an inquiry was sent to Monica Braverman, CEO of Defendant  Netunim, d/b/a/ DataShark regarding the statements made by Mr. Berg as to the  source of the motor vehicle record data that Defendant BB Direct Inc. obtained,  re-disclosed, and re-sold to BlackBook, Defendant TaCito & Associates, and  Defendant Don Herring Ltd. for uses that included, but not limited to, sending a  solicitation letter to Plaintiff Lopez. Mrs Braverman didn’t respond.    8. whether Defendant Don Herring Ltd. had a DPPA permissible use to obtain, re- disclose, and/or resell Plaintiff and Class Member's personal information contained  within motor vehicle records maintained by the State motor vehicle departments;   8. Sharon Taylor et. al. v. ACS State & Local Solutions, Inc. et. al., 2:07-cv-0013, (E.D.  Tex. 2007), a Federal Class Action involving similar underlying facts as the present  action, about 50 companies, violations of the Driver's Privacy Protection Act  ("DPPA"), 18 U.S.C. § 2721, et seq.;   83. The legislative history of the DPPA makes it clear that it incorporated “the intentions  of the 1972 Privacy Act…[And also] include[d] the recommendations of the 1977  Privacy Protection Study Commission [(PPSC”)] report.” The goal was to prohibit  disclosure of “records” collected and maintained by a Government agency, expect  under permissible circumstances. See 5 U.S.C. § 552a (b). The PPSC report  recommended that third party record holders be held to the “same standard” as the  Government in order to ensure compliance with the important statutory protections.  Personal Privacy is an Information Society: The Report of the Privacy Protection Study  Commission Ch. 13 (July 1977).   84. His literal reading of the DPPA was designed to promote public safety and to protect  individual privacy, construed so as to maximize his deterrent effect – in particular, by  shifting burdens to institutional actors who regularly engage in the targeted conduct  or are otherwise in a position to minimize future violations.   85. Congress intended the states to be the “gatekeepers” of the motor vehicle records,  limiting the number of people with access to the personal information because the  greater the number of people with access, the greater the risk that personal  information will be disseminated to those who do not have valid uses for the personal  information.   87. In each sentence of section 2721(c) Congress linked the term “Authorized Recipient”  to the specific section of 2721(b) that had authorized the release of the information to  the recipient. Congress intended that the “Authorized Recipients” to be individuals,  entities, or his agents, qualified to receive the information by the terms of section  2721(b). Resellers cannot obtain all of the personal information in the database simply  by calling himself resellers. Entities requesting motor vehicle records have to justify his  receipt of personal information under the 2721(b) exception is applicable. Defendants  were not “Authorized Recipients.”   89. To ensure that the privacy of driver records is adequately protected under the          DPPA, it was necessary to impose a high standard of duty for resellers when the  records they sell are subsequently used for impermissible purposes, due in part  because an industry of “resellers” had arisen to facilitate acquisition by end-users of  information collected by State Motor Vehicle Bureaus. As the reseller is in the best  position to determine whether the subsequent use of the data would be permissible  under the Act, it is the reseller that must bear the burden of ensuring that an  impermissible use does not occur and must investigate to determine if entities  requesting the motor vehicle records have a DPPA permissible purpose. The state  agency ceases to be the custodian of the data once it is obtained by the reseller; the  reseller must therefore assume the responsibility and the liability for the subsequent  use of the data resulting from its intentional resale, especially as it relates to direct  marketing. The civil remedies provision would be rendered “toothless” if resellers  could insulate himself from liability based solely on conclusory representations of end  users, without being required to exercise due care himself.   9. Sharon Taylor et. al. v. Texas Farm Bureau Mutual Insurance Company et.al.,  2:07-cv-0014, (E.D. Tex. 2007), a Federal Class Action involving similar underlying  facts as the present action, about 50 companies, violations of the Driver's Privacy  Protection Act ("DPPA"), 18 U.S.C. § 2721, et seq.;     9. whether Defendants Monica Braverman obtained the written express consent of  Plaintiff and Class Members to obtain, re-disclose, and/or resell Plaintiff and Class  Member's personal information contained within motor vehicle records maintained  by the State motor vehicle departments;   91. In light of the text, structure, and legislative history of the DPPA, resellers are subject  to a duty of reasonable care before disclosing DPPA-protected personal information,  18 U.S.C. §2721(b)-(c). Resellers must exercise reasonable care in responding to  requests for personal information drawn from motor vehicle records. Resellers are  liable if they do not secure proof that representations made by the recipient of  personal information was valid. Defendants failed to exercise such reasonable care  when reselling the motor vehicle records.    92. The structure of the DPPA supports the conclusion that resellers owe a duty of  reasonable care when reselling motor vehicle records to third parties. The DPPA  statute uses the word “knowingly,” revealing that a level of duty of care exists. The  DPPA provides an award of “punitive damages upon proof of willful or reckless  disregard of the law.” 18 U.S.C. § 2724(b)(2); In contrast, the court may award “actual  damages, but not less than liquidated damages in the amount of $2,500.” 18 U.S.C. §  2724(b)(1). The actual damages provision is silent as to the degree of fault necessary  to trigger liability for actual damages. If, however, as the statute suggests, punitive  damages are available only for willful and reckless violations of the DPPA, then actual  damages must require something less—that is, conduct that is neither willful nor  reckless.    94. Section 2721(c) does not suggests that a reseller may re-disclose protected  information so long as its customer claims to have a permissible use. Rather, the DPPA  authorizes the resale of information only if there is an actual, not just a stated,  permitted use. 18 U.S.C. § 2721(c); Thus, as a purely textual matter, the DPPA  indicates that a reseller who sells protected information to a client without an actual  permissible purpose is liable regardless what “certifications” that client has made.    95. Resellers owe the same or similar legal duty that obligates the State Motor Vehicle  Department’s when releasing motor vehicle records, that is to investigate fully  whether individuals or companies obtaining the motor vehicle records have a DPPA  permissible purpose. As the motor vehicle records are resold, in whole or part, the  likelihood of misuse grows exponentially. The DPPA provides no distinction as to  obligations of the end-user, resellers, nor the State Motor Vehicle Departments, as  Custodian of the motor vehicle records, Gordon v. Softech Int'l, Inc., U.S., No. 13- 533, cert. den. 1/13/14; Arcanum Investigations, Inc. v. Gordon, U.S., No. 13-539, cert.  den. 1/13/14).   97. To verify the eligibility to invoke the claimed DPPA permissible purpose, an entity must  provide information, including but not limited to, proof relating to its business which  must correspond to its claimed DPPA uses, current status, activity of the employing  entity, and purported business affiliation. It is negligent if the reseller fails to make  proper inquiries of the end-user, especially if “red flags” exist, and provide “red flags”  requiring additional review prior to the purchase of the Plaintiff and Class Members’  MVRs.    98. Defendants obtained the MVRs for a reason and with a purpose in mind. Federal Law  required Defendants, acting as “re-sellers’, to obligate National Affiliates to use the  requested MVR information for purposes permitted by the DPPA. Hence, at a  minimum, Defendants and National Affiliates disclosures were not permitted by the  DPPA permitted uses, and totally incompatible with the purpose for which the  information was collected.   A.  Introduction  