Adams v. Experian Information Solutions, Inc.

CourtDistrict Court, E.D. California
DecidedJanuary 2, 2025
Docket2:23-cv-01773
StatusUnknown

This text of Adams v. Experian Information Solutions, Inc. (Adams v. Experian Information Solutions, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adams v. Experian Information Solutions, Inc., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 DR. DERRICK ADAMS and CAPE No. 2:23-cv-01773-DJC-MJ EMERGENCY PHYSICIANS P.A., on 12 behalf of himself and those similarly 13 situated, ORDER GRANTING MOTION TO 14 Plaintiffs, DISMISS WITH LEAVE TO AMEND 15 v. 16 EXPERIAN INFORMATION 17 SOLUTIONS, INC., et. al., 18 Defendants. 19 20 Plaintiffs Doctor Derrick Adams and Cape Emergency Physicians, P.A. (“Cape”) 21 bring this putative class action complaint against Defendants Experian Information 22 Solutions, Inc., Equifax Inc., and TransUnion, alleging that they illegally combined 23 together to restrain trade by agreeing to no longer report medical debt less than 24 $500 and to not report medical debt until 365 days have passed. Plaintiffs argue that 25 this “Agreement” violates both federal and state antitrust laws. As discussed below, 26 while Plaintiffs have Article III standing to bring suit, they fail to make the more 27 rigorous showing that they have antitrust standing under federal law. Therefore, the 28 Court will dismiss Count One of the Amended Class Action Complaint, which brings a 1 federal claim under the Clayton Act, with leave to amend. As for Count Two, which 2 brings a state law claim under California’s Cartwright Act, the Court declines to 3 exercise supplemental jurisdiction over it under 28 U.S.C. Section 1367(c)(3), although 4 Plaintiffs may reallege it in the event that they reassert their federal claim in a Second 5 Amended Class Action Complaint. 6 Accordingly, for the reasons set forth below, the Court GRANTS Defendants’ 7 Motion to Dismiss (ECF No. 48) as to Count One but DENIES as moot the Motion as to 8 Count Two. Plaintiffs are granted leave to amend if they so choose. 9 BACKGROUND 10 I. Factual Background 11 A. The Parties 12 The two Plaintiffs seek to represent medical service providers across the nation. 13 (See Am. Class Action Compl. (ECF No. 43) ¶¶ 68–84 (“Amended Complaint” or “AC”) 14 (providing the class allegations).) Each represents a different portion of the market. 15 Cape Emergency Physicians, P.A. is a New Jersey corporation domiciled there. 16 (See AC ¶ 17.) Cape provides emergency medical services. (See id. ¶ 24.) Doctor 17 Derrick Adams is the sole doctor in a medical practice in the small city of Lincoln, 18 California, near Sacramento. (AC ¶ 22.) Adams is a dermatologist who describes his 19 practice, “like that of many medical providers, [a]s a small business.” (Id. ¶ 51.) 20 Adams “frequently performs services that cost patients less than $500 out of pocket.” 21 (Id.) That $500 threshold is significant because the three largest credit reporting 22 agencies, Defendants, agreed to no longer report unpaid medical debt that was less 23 than $500. (See id. ¶¶ 4–5.) At base, Adams complains that he, like other medical 24 service providers who are solo- or small-scale practitioners, faces increased costs 25 trying to collect outstanding payments that will push him out of the market. (See id. 26 ¶¶ 6, 52, 58 (citation omitted); also id. at 51 (citation omitted).) 27 Defendants Experian, Equifax, and TransUnion are known as the “Three Credit 28 Reporting Agencies” or “CRAs.” (See AC ¶¶ 18–20; e.g., id. ¶¶ 4, 32.) Defendants are 1 recognized as the only significant actors in the credit reporting industry, which makes 2 the industry an oligopoly and gives them substantial control over an important part of 3 the economy. (See id. ¶¶ 63–67.) 4 B. The Product or Service and the Market 5 Plaintiffs allege that there is “one relevant market: the market for providing and 6 receiving medical-debt information for the purpose of reporting it on consumer credit 7 reports.” (AC ¶ 60.) “Medical providers, such as Plaintiffs, [allegedly] conduct a 8 transaction with [the CRAs] to provide medical-debt information in return for the 9 [CRAs] reporting it on consumer credit reports.” (Id.) “Medical providers submit 10 information about unpaid medical bills to [the CRAs] in what had been a mutually 11 beneficial transaction[.]” (Id. ¶ 7.) The CRAs “received information about unpaid 12 debts, which made their reports more valuable to those purchasing the credit reports, 13 and medical providers received help persuading patients to pay their medical bills, by 14 virtue of patients’ desire to avoid the negative impact of having unpaid medical bills 15 on their credit reports.” (Id.) The relevant market spans the United States and does 16 not include information about non-medical debts. (AC ¶¶ 60–61.) 17 C. The Defendants’ Agreement 18 This case revolves around two alleged conspiracies that form Defendants’ 19 “Agreement:” (1) the “reporting-amount conspiracy” and (2) the “reporting-timing 20 conspiracy.” (See AC ¶¶ 4–5.) In the “reporting-amount conspiracy,” Plaintiffs allege 21 that the CRAs “announced a formal agreement among themselves to restrain trade by 22 refusing to report unpaid medical bills under $500 on consumer credit reports.” 23 (Id. ¶ 4.) In the “reporting-timing conspiracy,” Plaintiffs allege that the CRAs “agreed 24 to extend the time that any amount of unpaid medical debt must be delinquent 25 before it can be reported on a consumer credit report, from 180 to 365 days.” 26 (Id. ¶ 5.) 27 In March 2022, the CRAs announced via press release the “joint measures” 28 covering the conspiracies. (AC ¶ 34 (citation omitted).) Later, the CRAs “jointly 1 instructed those who provided medical debt information to them: ‘Do no report 2 Medical Debt collection accounts . . . until they are at least 365 days past the Date of 3 the First Delinquency with the original creditor . . . .’” (Id. ¶ 36 (citation omitted).) 4 Those instructions also stated: “Do not report Medical Debt collection 5 accounts . . . under a pre-defined minimum threshold (will be at least $500 and 6 published later this year).” (Id.) Finally, in April 2023, the CRAs “jointly announced via 7 press release that they had effectuated their joint commitment from 2022 not to 8 report medical debt under $500[.]” (Id. ¶ 37 (citation omitted).) 9 D. The Alleged Harm from the Agreement 10 Plaintiffs complain that a “substantial number of bills that Plaintiffs’ practices 11 have sent to patients, and will continue to send, are for an amount under $500.” 12 (AC ¶ 25.) “If patients do not pay their bills, Plaintiffs’ practices [allegedly] use third- 13 party accounts-receivable services as their agents to attempt to collect the unpaid 14 bills.” (Id. ¶ 28.) “Accounts-receivable, as one of their options for incentivizing 15 patients to pay their bills, report unpaid medical bills to [the CRAs].” (Id. ¶ 29.) 16 “Plaintiffs intend, and prefer, that accounts-receivable services, who [allegedly] work 17 as [Plaintiffs’] agents, continue to report their patients’ unpaid bills to the [CRAs].” 18 (Id. ¶ 33.) However, Plaintiffs allege that doing so is now pointless because of the 19 Agreement. (See id.) 20 Plaintiffs allege that the reporting-amount conspiracy harms medical service 21 providers because reporting unpaid medical debt was a “valuable tool that medical 22 providers use to incentivize patients to pay their bills.” (AC ¶ 50.) Without this tool for 23 debt less than $500, Plaintiffs allege that they “must resort to costlier methods to 24 receive payment of their bills, such as employing additional time of in-house staff and 25 third-party accounts-receivable services.” (Id.) As a result, Plaintiffs complain that they 26 “now receive less payment of medical bills and have a costlier path to collect payment 27 on unpaid medical bills, if they can feasibly collect at all.” (Id.

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Adams v. Experian Information Solutions, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/adams-v-experian-information-solutions-inc-caed-2025.