8/3/2019 Request for Credit File From Innovis

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8/3/2019 Request for Credit File From Innovis

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information proving the identity of that individual. For purposes of this statute,consumer reporting agency is defined in relevant part as any person which, formonetary fees, due, or on a cooperative nonprofit basis, regularly engages in whole or inpart in the practice of assembling or evaluating consumer credit information or otherinformation on consumers for the purpose of furnishing consumer reports to third parties .

. ., and a credit file is defined as all information on [a] consumer recorded andmaintained by a consumer reporting agency regardless of how the information is stored.15 USC 1681a(f), (g). Similarly, California state law also requires that a consumer creditreporting agency promptly disclose to a consumer all files maintained on that consumerby the credit reporting agency. California Civ. Code 1785.15(b).

It is absolutely clear from merely a cursory inspection of the information displayed onyour own company web site that Innovis is a repository of consumer credit informationand files, and a result of its disclosure of such information to prospective third partycredit providers, is a consumer reporting agency for purposes of both the federal FCRAand parallel California law. As such, Innovis is unconditionally obligated under both of

these statutory authorities to disclose to me the complete contents of all files whichInnovis maintains on me. The failure and/or refusal of Innovis to disclose thisinformation makes available to me a number of remedies including, under Californiastate law: (i) actual damages, including court costs, loss of wages, attorneys fees and,when applicable pain and suffering, (ii) if the failure to disclose is willful, punitivedamages of up to Five Thousand Dollars ($5,000), and (iii) injunctive relief. CaliforniaCiv. Code 1785.31(a)(1), (2), and (3). In addition, in the case of a class action claim, theclass claimants may seek punitive damages. California Civ. Code 1785.31(c).

In light of the above, I hereby demand that Innovis immediately disclose to me any andall credit files and/or information which it is maintaining on me. Should you fail and/orrefuse to timely make this disclosure as mandated by law, I will avail myself of all of mylegal rights and remedies in order to compel you to disclose this information to me. Youcan easily avoid the significant expense, effort, and negative publicity associated withhaving to respond to such actions by simply fulfilling your legally mandated obligations.I trust that you would prefer to comply with the law voluntarily rather than to have acourt of law force you to do so.

I look forward to your expeditious handling of this extremely serious matter.

Very truly yours,

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