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ARTICLE · 25 JUNE 2013

Furnisher’s Reliance On The ACDV Without Supportive Investigation Testimony Not Enough To Win On Summary Judgment

There is "no private right of action" under §1681s-2(a), because the duties imposed under this statute are only enforceable by a governmental agency or official.

United StatesLitigation, Mediation & Arbitration

Peter Dickman v. Verizon Communications, Inc. dba Verizon Wireless, 2012 U.S. Dist. LEXIS 90188 (E.D. NY. Jun. 28, 2012)

Facts: Plaintiff Peter Dickman alleged that Defendant Verizon Communications, Inc. ("Verizon") violated 15 U.S.C. §§1681s-2(a) and (b) of the FCRA, by furnishing inaccurate information to the credit reporting agencies ("the CRAs") and failing to delete inaccurate information. Plaintiff also alleged that Verizon engaged in deceptive business practices in violation of New York General Business Law § 349 by failing to maintain reasonable procedures designed to assure maximum possible accuracy of Plaintiff's credit information. Plaintiff filed suit over the negative credit reporting of a Verizon phone/DSL account that he believed had been terminated. Verizon agreed that Plaintiff's old account terminated, but claimed that Plaintiff opened a new account soon thereafter and was sent billing statements which went unpaid. Verizon's representative provided

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