In Syed v. M-I, LLC,the Ninth Circuit held that the Fair Credit and Reporting Act rights notice cannot be combined with any other notice or agreement. In determining that the violation was willful, the Court held that the “ordinary meaning of ‘solely’ is alone; singly or entirely; exclusively.” In this case, an applicant applied for a position and completed a “Pre-Employment Disclosure Release.” Soon after signing, the applicant commenced a putative class action, alleging that inclusion of the liability waiver in the same document as the disclosure statement violated FCRA.

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