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In Farmer v. The Phillips Agency, the U.S. District Court for the Northern District of Georgia denied a plaintiff’s motion to certify a class action, under the Fair Credit Reporting Act, consisting of all individuals who had been the subject of an adverse criminal-background report, whether accurate or inaccurate, generated by defendant The Phillips Agency. In doing so, the Northern District of Georgia became the first court to explicitly state that a plaintiff bringing claims under the FCRA must establish that the underlying consumer report was not "complete and up to date."
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