¶ 40.) She explains that Experian's "inaccurate reporting completely derailed" her attempts to obtain a loan modification of her home mortgage because when the loan servicer asked Hill-Green to provide documentation for the business, she could not do so. and had no knowledge of anything about it." 3 ( Id. ¶¶ 36, 50.) Hill-Green avers that she "has no association with ICM, Inc. Hill-Green alleges that she suffered harm when Experian, using its Fraud Shield product, identified her as a fraud risk on her credit report by flagging her home address as a business address associated with a defunct "mailing and shipping services business called ICM, Inc." ( Id. Hill-Green's Experience with Experian's Fraud Shield In the Complaint, Hill-Green describes both her experience with Experian's use of its Fraud Shield product on her credit report and two subsequent disputes that she made to Experian regarding information that appeared on her Experian credit report. Allegations as to Hill-Green's Personal Experience with Experian ¶ 25.) She maintains that "Experian rarely, if ever, manually review its files to ensure all antedated adverse address information is deleted from consumer files." ( Id. ¶ 21.) She asserts that "he methods and processes that Experian uses to gather and compile derogatory address information are automated." ( Id. Hill-Green alleges "pon information and belief," that "Experian identifies a consumer's address as `high-risk' without any procedure to assure the accuracy or completeness of the information with respect to the individual about whom the report relates." ( Id. ¶ 23.) "This information is used by creditors to determine a consumer's credit worthiness and also provides creditors with information concerning a consumer's personal characteristics and general reputation." ( Id. ¶ 20.) "Experian then reports the `high-risk business' on the consumer's credit report." ( Id. ¶ 18.) Experian's Fraud Shield "identifies an address as `high-risk' when its File One Database associates the address with a business or one of its `30 high-risk address profiles.'" ( Id. ¶ 17.) "Among other things, Fraud Shield: (1) screens and identifies `more than 30 high-risk address profiles,' (2) flags telephone and social security numbers, and (3) `dentifies recent authorized user tradeline information to highlight potential credit boosting schemes.'" ( Id. ¶ 14.) "Through Experian's File One Database, `which houses more than 215 million active consumer profiles,' Fraud Shield `utilizes predictive crosschecking' to help potential creditors `reduc fraud losses.' ( Id. 1.) Hill-Green alleges that Experian sells this product "to inform credit, employment, and other decisions that companies make about borrowers." ( Id. Hill-Green states that Experian "developed, markets, and sells" a product known as "Fraud Shield," that Experian describes "as identifying `high-risk characteristics' by "using `the power of predictive indicators and scoring to provide specific high-risk characteristic descriptions.'" (Compl. General Allegations as to Experian's Fraud Shield Hill-Green's class claims focus primarily on Experian's use of an Experian product, known as "Fraud Shield," while her individual claim focuses on Experian's response to two disputes she made regarding information appearing on her Experian credit report.
In her three-count FCRA Complaint, Hill-Green brings two claims on behalf of herself and Virginia-based classes and another claim solely on behalf of herself. 2 For the reasons that follow, the Court will deny the Motion to Transfer. The Court exercises jurisdiction pursuant to 28 U.S.C. The Court dispenses with oral argument because the materials before it adequately present the facts and legal contentions, and argument would not aid the decisional process. 8.) Plaintiff Lisa Hill-Green responded, (ECF No.
§ 1404 1 and Under the First-to-File Rule or, in the Alternative, to Stay Action (the "Motion to Transfer"). This matter comes before the Court on Defendant Experian Information Solutions, Inc.'s ("Experian") Motion to Transfer Venue Pursuant to 28 U.S.C.
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