The District of Massachusetts denied a defendant’s motion to dismiss or to strike class claims in a putative Fair Credit Reporting Act (FCRA) action in McIntyre v. RentGrow, Inc., No. 18-cv-12141-ADB. The complainant in the case alleged that the defendant’s purchase of eviction information that was not updated, with knowledge of the errors, resulted in inaccurate screening reports that unfairly harmed thousands of tenants. The Court determined that the class claims in the complaint met the requirements of Rule 8 and that the complaint should survive the defendant’s motion to dismiss under Rule 12(b)(6). Despite the absence of other identified tenants or reports, the Court declined the defendant’s request to strike the complaint’s class allegations under Rule 12(f), observing that “discovery can show whether the inaccuracies alleged were widespread and similar enough to support class certification.”
