Durphey v. Experian Information Solutions Inc

CourtDistrict Court, W.D. Washington
DecidedJanuary 24, 2025
Docket2:24-cv-00468
StatusUnknown

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

Bluebook
Durphey v. Experian Information Solutions Inc, (W.D. Wash. 2025).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 VERONICA DURPHEY , CASE NO. C24-468 MJP 11 Plaintiff, ORDER ON DEFENDANT EXPERIAN INFORMATION 12 v. SOLUTIONS, INC.’S MOTION TO COMPEL ARBITRATION AND 13 EXPERIAN INFORMATION MOTION TO STAY DISCOVERY SOLUTIONS, INC., et al., 14 Defendants. 15

16 This matter comes before the Court on Defendant Experian Information Solutions, Inc.’s 17 Motion to Compel Arbitration (Dkt. No. 50), and Motion to Stay Discovery (Dkt. No. 52). 18 Having reviewed the Motions, the Oppositions (Dkt. Nos. 54), the Replies (Dkt. Nos. 56, 57), the 19 Supplemental Briefs (Dkt. Nos. 64, 67), the Notices of Supplemental Authority (Dkt. Nos. 71 20 72), and all supporting materials, the Court GRANTS Experian’s Motion to Compel Arbitration 21 and DENIES AS MOOT Experian’s Motion to Stay Discovery. 22 23 24 1 BACKGROUND 2 Plaintiff Veronica Durphey has brought claims under the Fair Credit Reporting Act 3 (FCRA) against four different consumer reporting agencies (CRAs) for inaccurately reporting 4 that she was deceased and did not have a credit score. Although she settled with two CRAs—

5 Equifax Information Services LLC and LexisNexis Risk Solutions, Inc.—she still pursues claims 6 against Experian Information Solutions, Inc., and TransUnion LLC. 7 Between February and March 2023, Durphey discovered through a credit monitoring 8 service that her credit score would periodically drop to “0”. (Complaint ¶ 86 (Dkt. No. 1).) She 9 reached out to TransUnion and was told that this was due to a “glitch.” (Id. ¶¶ 88-89.) But in 10 August 2023, she was denied auto insurance by Farmers Insurance because a consumer credit 11 report it obtained from LexisNexis reported Durphey was deceased. (Id. ¶¶ 94-101.) Similarly, in 12 response to Durphey’s request for auto insurance, TransUnion published information to Hartford 13 Insurance Co. that Durphey was deceased and Experian reported the same to Commerce West 14 Washington. (Id. ¶¶ 105-08.) Durphey alleges that she disputed the credit information with all of

15 these CRAs and that their response was not reasonable. (Id. ¶¶ 117-79.) 16 Durphey brings two claims under the FCRA: (1) Defendants failed to follow reasonable 17 procedures to report accurate information (Compl. ¶¶ 212-22); and (2) Defendants failed to 18 perform a reasonable reinvestigation (Id. ¶¶ 223-33.) 19 Defendant Experian now moves to compel arbitration of all Durphey’s claims against it. 20 (Dkt. No. 50.) It argues that Durphey agreed to arbitrate her claims when she signed up to 21 receive credit monitoring services from an affiliate entity, Experian Consumer Services (ECS). 22 Because the Motion to Compel Arbitration turns on this alleged agreement, the Court examines it 23 in some detail.

24 ] Durphey enrolled in credit monitoring services from non-party Experian Consumer 2 || Services in 2016. (Declaration of Veronica Durphey § 2 (Dkt. No. 55-2).) She claims that she 3 || was not aware she agreed to an arbitration provision and that if she knew she would waive her 4 || right to a jury trial, she would not have signed up for the services. (Id. §{ 3-7.) Experian’s 5 || corporate witness, Dan Smith, explains that Durphey enrolled in Experian Credit Services’ 6 || “CreditWorks” service on December 23, 2016 and continued to be enrolled until January 18, 7 || 2024. (Declaration of Dan Smith ff 3, 5 (Dkt. No. 51).) Smith, who has been Experian since 8 explains that he is familiar with the “consumer enrollment process into CreditWorks” and 9 || the steps a consumer would have had to take in 2016 to enroll. (Smith Decl. ¥ 1.) According to 10 || Smith, Durphey would have had to accept the Terms of Service in order to enroll. (Id. § 3.) The 11 || website required Durphey to enter personal information on two successive web pages. (Id. {ff 3- 12 || 4.) After entering some personal information on the first webpage, the second required her to 13 || create an account and accept the Terms of Use Agreement. (Id. 4.) The following was disclosed 14 || to her: 15 By clicking "Submit Secure Order": | accept and agree to your Terms of Use 16 Agreement, as well as acknowledge receipt of your Privacy Policy and Ad Targeting Policy. | authorize ConsumerlInfo.com, Inc., also referred to as 17 Experian Consumer Services ("ECS"), to obtain my credit report and/or credit score(s), on a recurring basis to provide them to me for review while | 18 have an account with ECS. | also authorize ECS to obtain and use the information | provide, and my credit report and/or credit score(s), ona 19 recurring basis to notify me of credit opportunities and other products and services that may be available to me through ECS or through unaffiliated 20 third parties. | understand that | may withdraw this authorization at any time by contacting ECS. 21 22 eaali -1e0 1M] 23 24

ORDER ON DEFENDANT EXPERIAN INFORMATION SOLUTIONS, INC.’S MOTION TO COMPEL

1 (Smith Decl. Ex. 2.) In order to complete enrollment, Durphey had to press the “Submit Secure 2 Order” button. (Id.) 3 The Terms of Use Agreement in effect in 2016 stated “ECS and you agree to arbitrate all 4 disputes and claims between us arising out of this Agreement directly related to the Services or

5 Website[.]” (Smith Decl. Ex. 3 at 1 (Dkt. No. 51-1 at 6).) But the Agreement expressly carved 6 out FCRA claims: “for avoidance of doubt, any dispute you may have with us arising out of the 7 Fair Credit Reporting Act (FCRA) relating to the information contained in your consumer 8 disclosure or report, including but not limited to claims for alleged inaccuracies, shall not be 9 governed by this agreement to arbitrate.” (Id.) 10 While this might upend Experian’s arbitration request, it argues that Durphey agreed to 11 an updated Terms of Use Agreement issued in 2019 that no longer carved out FCRA claims. 12 Smith points out that by 2019, the Agreement was updated to remove this language. (Smith Decl. 13 ¶¶ 7, 9 & Ex. 5.) The 2019 Terms of Use Agreement states: “ECS and you agree to arbitrate all 14 disputes and claims between us arising out of this Agreement directly related to the Services or

15 Websites to the maximum extent permitted by law[.]” (Ex. 5 at 4 (Dkt. No. 51-1 at 59).) This 16 includes “claims arising out of or relating to any aspect of the relationship between us arising out 17 of any Service or Website, whether based in contract, tort, statute . . . or any other legal theory; 18 claims that arose before this or any prior Agreement . . . .” (Id.) And the Agreement explained 19 that “[f]or purposes of this arbitration provision, references to ‘ECS,’ ‘you,’ and ‘us’ shall 20 include our respective parent entities, subsidiaries, affiliates. . . .” (Id.) According to Experian 21 Durphey agreed to these new terms because the 2016 Agreement gave notice that her continued 22 use of Experian’s services would bind her to any modification. Specifically, the 2016 Agreement 23 stated “[t]his Agreement may be updated from time to time” and “[e]ach time you order, access

24 1 or use any of the Services or Websites, you signify your acceptance and agreement, without 2 limitation or qualification, to be bound by the then current Agreement.” (Smith Decl. Ex. 3; see 3 Smith Decl. ¶ 7.) 4 To help explore this question of whether Durphey agreed to the updated Terms of Use

5 Agreement, the Court requested additional briefing concerning how Durphey was given notice of 6 and allegedly agreed to the updated Terms of Use. In support of its supplemental brief, Experian 7 filed a new declaration from Smith, in which he claims that Durphey agreed to the changes in the 8 arbitration provision. Specifically, Smith states that Durphey received the following email: 9 \\ 10 \\ 11 \\ 12 \\ 13 \\ 14 \\

15 \\ 16 \\ 17 \\ 18 \\ 19 \\ 20 \\ 21 \\ 22 \\ 23 \\

24 1] From: Experian

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