Rogers Ikea Vs National Tenant Netw Ork, Inc.

This is a consumer class action brought pursuant to the Fair Credit Reporting Act,

15 U.S.C. §§ 1681-1681x (“FCRA”) and the New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1

et seq. (“NJCFA”), by Plaintiff, seeking relief for Defendant’s widespread violations thereof for

herself and all others similarly situated.

Despite the public availability of court records that conclusively demonstrate that

certain eviction cases have been dismissed, withdrawn, vacated, satisfied, or resulted in judgments

for tenants, Defendant routinely fails to obtain up-to-date information pertaining to the disposition

of those cases and publishes harmful, misleading, and inaccurate tenant screening reports to

landlords in violation of FCRA section 1681e(b).

GLO-L-000765-24 06/14/2024 5:01:59 PM Pg 2 of 18 Trans ID: LCV20241504551

Similarly, although the final disposition (or lack of a disposition) of a criminal

charge is available on the regularly-updated public court record of criminal proceedings, Defendant

routinely fails to consult such records and thus publishes harmful, misleading, and inaccurate

criminal record information on reports, even where the criminal charge did not result in a conviction

and predates the report by more than seven years, in violation of FCRA section 1681c(a)(5).

Defendant compounds this misreporting by failing to provide consumers with a

clear and accurate disclosure of all information on file about them, including the original and any

intermediate sources of such information, upon such consumers’ request as required by FCRA

section 1681g(a)(2). Instead, Defendant fails to identify the court(s) from which such records

originate, and to identify any intermediate private vendor sources of information which may be the

source of inaccuracies on the report. Defendant’s failure to provide complete disclosures impairs

consumers’ rights under the FCRA to dispute such information and have it corrected at the source

to prevent future misreporting.

Defendant’s unlawful conduct as described above constitutes a violation of the

NJCFA and furthermore represent unconscionable commercial practices prohibited under N.J. Stat.

§ 56:8-2.

Defendant’s practices harm consumers seeking residential leases by prejudicing

their prospective landlords with inaccurate and/or irrelevant adverse information.

I. JURISDICTION and VENUE

This Court has jurisdiction over this matter because Defendant regularly conducts

business in the State of New Jersey. National Tenant Network, Inc. (“NTN”) is a consumer

reporting agency which regularly conducts business in the District of New Jersey and has a

principal office located at 188 Fries Mill Road, Turnersville, NJ 08012, and at all times relevant,

acting alone or in concert with others, formulated, directed, concealed, controlled, conspired,

Causes of Action

V. CLAIMS for RELIEF

COUNT I – VIOLATION of FCRA SECTION 1681e(b)

COUNT II – VIOLATION of FCRA SECTION 1681c(a)(5)

COUNT III – VIOLATION of FCRA SECTION 1681g(a)(2)

COUNT IV – DEFAMATION

COUNT V – VIOLATION of NEW JERSEY CONSUMER FRAUD ACT (N.J. Stat. §§ 56:8-1 et seq.)