The United States District Court for the Eastern District of Kentucky offered a reminder in the case of Shockley v. Portfolio Recovery Associates, LLC, 2018 WL 5726190 (E.D. Ky., No. 1, 2018) that there is no slam dunk when it comes to damages awarded in violations of the Fair Credit Reporting Act (FCRA). The plaintiff in the case was found to have adequately demonstrated that United Adjustment Corporation was in default for failing to respond to his complaint and was liable for violations of the FCRA and FDCPA. The Court, however, ruled that because “statutory damages do not constitute a sum certain,” UAC would be allowed to respond on the issue of damages.