Class actions alleging technical violations of the FCRA against employers who obtain consumer reports on job applicants are all the rage, generating large settlements and headlines. Perhaps bucking this trend, a federal judge in California recently dismissed a putative class action case in its infancy against Paramount Pictures Corporation. The plaintiff, Michael Peikoff, alleges Paramount breached the FCRA by procuring a consumer report without making the required disclosure. The court found that even if Paramount’s disclosure did not strictly comport with FCRA’s requirement, “it is not plausible that Paramount acted in reckless disregard of the requirements of the FCRA by using this language.” The court granted Paramount’s motion, and dismissed Peikoff’s complaint with prejudice.

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