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Motion of the Acting Solicitor General - Proof of Service

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Motion of the Acting Solicitor General, Proof of Service (U.S. Mar. 5, 2021)

No. 20-297 IN THE SUPREME COURT OF THE UNITED STATES TRANSUNION LLC, PETITIONER v. SERGIO L. RAMIREZ [See Attached Service List] CERTIFIC

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Brief of respondent Sergio L Ramirez - Main Document

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief of respondent Sergio L Ramirez, Main Document (U.S. Mar. 3, 2021)

Nonetheless, TransUnion took no steps to ensure greater accuracy of its product.

Regarding typicality, the court found that, although TransUnion referred to what it claimed were “a litany of unique facts involved with [Ramirez’s] claims,” including his interaction with the Nissan dealer, he was nonetheless typical under ...

Likewise, “[Ramirez’s] disclosure claims are based on what was in—or more precisely, what was not in— the consumer file Trans Union disclosed to Plaintiff along with the separate letter,” and accordingly, none of the purported ‘“unique ...

Although TransUnion does not dispute Article III standing for the 1,853 class members subject to the stipulation, it nonetheless maintains that the only thing class members had in common was that they received two envelopes instead of ...

Third, although the SG purports to rely on three treatises, none of them even arguably supports her premise that typicality is designed to protect defend- ants against impressive or sympathetic plaintiffs.

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Brief of respondent Sergio L Ramirez - Proof of Service

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief of respondent Sergio L Ramirez, Proof of Service (U.S. Mar. 3, 2021)

SERGIO L. RAMIREZ, individually and on behalf of all other similarly situated individuals, Respondent.

I HEREBY CERTIFY that on March 3, 2021, three (3) copies of the BRIEF FOR RESPONDENT in the above-captioned case were served, as required by US.

Supreme Court Rule 29.5(0), on the following:

KIRKLAND & ELLIS LLP 1301 Pennsylvania Avenue, NW Washington, DC 20004 Counsel for Petitioner

District of Columbia My commission expires April 14, 2022.

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Brief amicus curiae of Professional - Main Document

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of Professional, Main Document (U.S. Feb. 8, 2021)

Among other goals, PBSA members seek to promote the accurate and timely reporting of a variety of consumer- related information for the purpose of empowering employment, housing, insurance, credit and other financial opportunities to individuals across the country.

Amicus agrees with Petitioner that the vast majority of class members in this appeal fail to satisfy Article III standing because they did not suffer the requisite constitutional “concrete harm,” as clarified by this Court in Spokeo, Inc. v. Robins, 136 S.Ct.

This is the result of three primary factors: (i) the numerous exacting and specific technical requirements imposed by the FCRA; (ii) the uncapped class action damages available to prevailing plaintiffs; and (iii) the high volume nature of background screening.

As a result, amicus’ members often are left with a Hobson’s choice of (i) expending significant legal fees to defend against a no-injury class action (all the while having the prospect of a multi-million dollar judgment in the background) or; (ii) to settle a technical violation early and on an in terrorem basis.

In addition to the ongoing threat of no-injury class actions, the Ninth Circuit’s decision raises a new cost to the industry by potentially forcing members to defend Section 1681e(b) claims where they have not even communicated consumer information to a third party.

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Brief amicus curiae of The Product - Main Document

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of The Product, Main Document (U.S. Feb. 8, 2021)

PLAC’s perspective is derived from the experiences of a corporate membership that spans a diverse group of industries in various facets of the manufacturing sector.

Therefore, the mere existence of embarrassing and inaccurate infor- mation in a credit report is not sufficient to consti- tute an injury in fact just because it might (or might not) one day be disclosed to third parties before the information is corrected.

Ramirez himself might have suffered an injury as a result of Petitioner’s alleged failure to follow reasonable procedures to assure maximum accuracy.

The Ninth Circuit believed that the mere exist- ence of the “highly sensitive” information in the credit report, and the fact that it was “available to numerous potential creditors and employers” was “sufficient to show a material risk of harm to the concrete interests of all class members.” (Pet. App. at 26-27.)

The effect of these compounding errors, if al- lowed to persist, will inevitably be routine violations of the Rules Enabling Act and a denial of due process to either defendants or unnamed class members.

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Brief amicus curiae of National Consumer - Certificate of Word Count

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of National Consumer, Certificate of Word Count (U.S. Feb. 8, 2021)

SCP Tracking: Lawson-111 North Orange Ave.-Cover Light Green

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Brief amici curiae of The Home Depot Inc - Main Document

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amici curiae of The Home Depot Inc, Main Document (U.S. Feb. 8, 2021)

Where the named plaintiff brings an atypically strong claim, it is virtually certain that the jury’s damages findings will reflect the named plaintiff’s harms rather than the harms to plaintiffs whose lesser or nonexistent injuries were not before ...

After all, TransUnion would have had the opportunity to an- swer each plaintiff’s individual claim, and none of them would have been allowed to offer Ramirez’s 16 story of humiliation and cancelled vacation.

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