The Eleventh Circuit vacated a $490,000 punitive damages award last Friday for a single FCRA violation, finding that there wasn’t enough proof of a willful violation. Considering that the jury had initially awarded $3 million in punitives (which the trial court cut to $490,000 on due process grounds), this is a big win for Experian.

A recent case in the Northern District of Minnesota[1] helpfully confirmed that although consumer reporting agencies (“CRAs”) are required by the Fair Credit Reporting Act (“FCRA”) to ensure that the consumer reports are accurate, they are not obligated to include information on all (or any) credit accounts (or “tradelines”) relating to a consumer.