Complaint Against Equifax Information Services, LLC with Jury Demand Filed by Antonio Locke. (Attachments: # 1 Civil Cover Sheet)(Saks, Yaakov) (Attachment 1 Replaced on 4/1/2026)

substantial and regular business activities in this judicial district. Equifax is a Georgia corporation registered to do business in the state District of Columbia. Equifax’s principal place of business is located at 1550 Peachtree Street NW, Atlanta, GA 30309. 7.At all times material hereto, Equifax is a consumer reporting agency regularly engaged in

the business of assembling, evaluating and disbursing information concerning consumers for the purpose of furnishing consumer reports, as said term is defined under 15 U.S.C. § 1681a(f) to third parties. Equifax’s principal place of business is located at 1550 Peachtree Street NW, Atlanta, GA 30309.

Equifax’s Double Reporting Violation

identical open date of June 17, 2017, the same open balance of $567 and a credit limit of $501. 13.Both Capital One accounts also contain overlapping late payment notations. 14.The information published by Equifax is inaccurate since Plaintiff only opened one Capital

One account on June 17, 2017, yet the credit report contains duplicate reporting of the same negative account. 15. The information published by Equifax is inaccurate since the Capital One account is being

reported with an outstanding balances and derogatory notations in duplicate form on Plaintiff’s credit reports, making it appear that Plaintiff has more derogatory accounts on his report than he should. 16.Defendant listed Plaintiff’s single Capital One account as two (2) separate accounts, both

with outstanding balances and overlapping late payment notations. 17. Equifax is required by law to implement processes and procedures which maximize

possible accuracy of all reporting. 18. In addition to merely duplicating accounts on Plaintiff’s credit report, Equifax’s

duplication of derogatory accounts has a serious impact to Plaintiff’s perceived creditworthiness. 19. Equifax has been reporting this inaccurate information through the issuance of false and

inaccurate credit information and consumer reports that it has disseminated to various persons and credit grantors, both known and unknown. 20. Equifax failed to establish and implement reasonable procedures to ensure accurate

reporting of Plaintiff’s credit information. 21. Equifax violated 15 U.S. Code § 1681e(a)and(b) by failing to maintain and follow

reasonable procedures to avoid reporting inaccurate information regarding the consumer Plaintiff. 22. Had Equifax maintained and followed reasonable procedures to assure maximum possible

accuracy of the Plaintiff’s information, it would have been revealed to Equifax that the account in question was being reported in duplicate form. 23. Equifax is required to maintain maximum possible accuracy of consumer credit reports,

and this error should have been picked up internally by Equifax. 24.Additionally, the publication of this information is materially misleading, as anyone who

views this report would assume that the Plaintiff had two negative accounts. 25. Equifax published and disseminated such inaccurate information to other third parties,

persons, entities and credit grantors, as evidenced by the inquiries on the Plaintiff’s credit report in the form of hard and soft pulls. 26.As a result of Defendant’s failure to comply with the FCRA, the Plaintiff suffered concrete

harm in the form of loss of credit, loss of ability to purchase and benefit from credit, a chilling effect on applications for future credit, and the mental and emotional pain, anguish, humiliation and embarrassment of credit denial.

FIRST CAUSE OF ACTION (Willful Violation of the FCRA)

stated herein with the same force and effect as if the same were set forth at length herein. 28. This is an action for willful violation of the Fair Credit Reporting Act U.S.C. § 1681 et

seq. 29. Equifax violated 15 U.S.C. § 1681e(a) and (b) by failing to maintain or to follow

reasonable procedures to assure maximum possible accuracy in the preparation of the credit report and credit files that Equifax maintained concerning the Plaintiff. 30. Equifax willfully and recklessly failed to comply with the Act. The failure of Equifax to

comply with the Act includes but is not necessarily limited to the following: a) The failure to maintain reasonable procedures to assure the maximum possible

accuracy of the information reported; b) The failure to follow reasonable procedures to assure the maximum possible

accuracy of the information reported; c) The failure to remove and/or correct the inaccuracy and derogatory credit

information; d) The continual placement of inaccurate information into the credit report; e) The failure to promptly delete information that was found to be inaccurate, or could

not be verified; and f) The failure to take adequate steps to verify information Equifax had reason to

believe was inaccurate before including it in the credit report of the consumer. 31. As a result of the conduct, action and inaction of Equifax, the Plaintiff suffered damage

by loss of credit, loss of ability to purchase and benefit from credit, a chilling effect on