Theresa Tailford v. Experian Information Solutions, Inc.

CourtDistrict Court, C.D. California
DecidedMay 12, 2020
Docket8:19-cv-02191
StatusUnknown

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

Bluebook
Theresa Tailford v. Experian Information Solutions, Inc., (C.D. Cal. 2020).

Opinion

CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. SACV 19-02191JVS(KESx) Date 5/12/20 Title Theresa Tailford et al v. Experian Information Solutions, Inc.

Present: The James V. Selna, U.S. District Court Judge Honorable Lisa Bredahl Not Present Deputy Clerk Court Reporter Attorneys Present for Plaintiffs: Attorneys Present for Defendants: Not Present Not Present Proceedings: [IN CHAMBERS] Order Regarding Motion to Remand and Motion to Dismiss Plaintiffs Theresa Tailford, Sanford Buckles, and Jeffrey Ruderman (“Plaintiffs”) move to remand this action to State court. Mot., ECF No. 12. Defendant Experian Information Solutions, Inc. opposes the motion (“Experian”). Opp’n., ECF No. 18. Plaintiffs replied. Reply, ECF No., 20. Experian also moves to dismiss the complaint. MTD, ECF No., 11. Plaintiffs oppose the motion. MTD Opp’n., ECF No., 17. Experian replied. MTD Reply, ECF No. 19. For the following reasons, the Court DENIES the Motion to Remand, and GRANTS the Motion to Dismiss. I. BACKGROUND Plaintiffs filed their class action complaint in the Superior Court of the State of California, County of Orange (Case No.: 30-2019-01102976-CU-MC-CXC), alleging that Experian, a Credit Reporting Agency (“CRA”), violated the Fair Credit Reporting Act (“FCRA”). Compl., ECF No. 1-1. Experian removed the action to Federal Court on November 12, 2019. Removal, ECF No. 1. The Complaint asserts the following three claims: Count One, brought by Plaintiffs and Classes 1, 2, and 4: CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. SACV 19-02191JVS(KESx) Date 5/12/20 Title Theresa Tailford et al v. Experian Information Solutions, Inc. failing to include a list of all “soft” credit pulls on consumer disclosures for the 1-year period preceding the date of the request. (2) Violation of 15 U.S.C. §§ 1681g(a)(3) by failing to include the name of all persons who had procured a consumer report (or end-users of that report as defined under § 1681e(e)(1)) for the one-year period preceding the date of the request. (3) Violation of 15 U.S.C. §§ 1681g(a)(1) by failing to include all of the credit data it had stored related to consumers. Count Two, brought by Tailford, and Class 3: Violation of 15 U.S.C. §§ 1681g(a)(5) by failing to include a record of all inquiries received by it in the 1-year period that identified the consumer in connection with a credit or insurance transaction not initiated by the consumer. Count Three, brought by Tailford, Ruderman and Class 5: (1) Violation of 15 U.S.C. §§ 1681g(a)15) by failing to include the “employment dates” it had stored related to consumers. See id. ¶¶ 116-134. Experian collects “traditional” consumer credit data such as inquiries, public records, employers, and dates of reported employment in its “File One” database for purposes of determining a consumer’s creditworthiness. Id. at ¶ 27. Experian’s responses to credit inquiries are “at least in part” derived from this database. Id. Experian also provides consumer employment dates on another product called “Employment Insight” that Plaintiffs allege is a “consumer report.” Id. at ¶ 28. Plaintiffs contend that employment dates are of interest to prospective employers and that “Experian’s credit-scoring models have also listed the length of an applicant’s job as an ‘Adverse Action Reason,’ demonstrating that it can affect consumer creditworthiness.” CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. SACV 19-02191JVS(KESx) Date 5/12/20 Title Theresa Tailford et al v. Experian Information Solutions, Inc. A. The Behavioral Data Experian also collects “non-traditional” consumer data such as household income and purchase history (the “Behavioral Data”). Id. at ¶ 30. The Behavioral Data is sold to affiliates and third parties through a credit product called “OmniView” which includes a database called “ConsumerView.” Id. at ¶ 31. ConsumerView includes “thousands of attributes on more than 300 million consumers and 126 million households.” Id. Such information is Personally Identifiable Information because it either relates to individual consumers, or is derived from Personally Identifiable Information “which was stripped away prior to sale,” or can be combined with other “easily obtainable data to construct a comprehensive view of individual consumers.” Id. The ConsumerView database was formerly known as the “InSource Database” and Experian in a past public filing described it as “consumer socio-demographics, lifestyles, culture and behavior” data which it analyzes and categorizes into a compilation of datasets. Id. at ¶¶ 32-33. ConsumerView also includes Experian’s “Premier Aggregated Summarized Credit Statistics” which is a “series of aggregated credit attributes and proprietary scores that represent “the entire U.S. credit population.” Id. at 39. The product brochure from the Premier Aggregated Summarized Credit Statistics indicates that it is derived from “Experian’s National Consumer Credit File” and identifies its data source as the File One database. Id. at ¶ 40-42. It also states that the product “incorporates credit reporting agency data elements” such as available credit, collection activity, credit capacity, etc. Id. at ¶ 42. Plaintiffs contend that Experian offers the ConsumerView information “for the purpose of serving as a factor in determining eligibility for credit” because one offering of the product states that “summarized credit statistics are ‘calculated by aggregating the available consumer credit data in each Zip+4 and are most useful to identify prospects for invitations to apply for credit . . . offers.” Id. at ¶ 44. The data can be applied to “[t]arget candidates for invitations to apply for credit.” Id. Plaintiffs allegations as to the Behavioral Data contained in the ConsumerView product are best summarized in paragraph 45 of the Complaint: Although ConsumerView is purportedly a marketing database, the foregoing allegations make clear that the information CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. SACV 19-02191JVS(KESx) Date 5/12/20 Title Theresa Tailford et al v. Experian Information Solutions, Inc. purposes related to determining consumers’ eligibility for credit, employment, insurance, or other purposes articulated under Section 1681b of the FCRA. The non-traditional consumer information collected by Experian – including but not limited to education, income, and the type of residence a consumer lives in – has been used as a factor in determining consumer creditworthiness, in addition to its use as a marketing tool. Id. at ¶ 45. Experian also sells the consumer Behavioral Data through a suite of services called “Collection Advantage.” Id. at ¶ 36. Collection Advantage “permit[s] the user to combine data from Experian’s File One database and the database known as “MetroNet.” Id. MetroNet contains demographic information from “INSOURCE” the “nation’s largest repository of consumer marketing demographic data.” Id. B. Data Breach On October 6, 2017, UpGuard, a cyber-security research firm, discovered an Amazon cloud storage space that allegedly contained information regarding 123 million American households. Id. at ¶¶ 56-57. This data, allegedly placed in cloud storage by data analytics company Alteryx, was stored so as to be accessible to over one million specified users. Id.

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Theresa Tailford v. Experian Information Solutions, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/theresa-tailford-v-experian-information-solutions-inc-cacd-2020.