MEMORANDUM OPINION

M. HANNAH LAUCK, District Judge.

This matter comes before the Court on the Motion for Class Certification filed by Plaintiff Carolyn Clark, on behalf of herself and all similarly situated individuals. (ECF No. 66.) Defendant Trans Union, LLC ("TransUnion") has responded to the Motion for Class Certification, (ECF No. 82), and Clark has replied, (ECF No. 104). The Court heard oral argument on February 23,2017. Accordingly, the matter is ripe for disposition. The Court exercises jurisdiction pursuant to 28 U.S.C. § 1331.1 For the reasons that follow, the Court will grant the Motion for Class Certification.

I. Procedural and Factual Background2

A. Procedural Background

Clark, the named plaintiff, asserts six counts against TransUnion: one proposed class claim and five individual claims. Count I, the "Disclosure of Sources Claim" or the "Class Claim" alleges a putative class action arising out of TransUnion's violations of 15 U.S.C. § 1681g(a)(2)3 of the FCRA, which requires that consumer reporting agencies "clearly and accurately" disclose to consumers "[t]he sources of information" in their credit files. 15 U.S.C. § 1681g(a)(2). Clark alleges that TransUnion's violations of § 1681g(a)(2) entitle each consumer who received his or her credit file with incorrect source information to statutory damages under § 1681n(a) between $100 and $1,000.4

Following the Supreme Court of the United States' opinion in Spokeo, Inc. v. Robins, 136 S.Ct. 1540 (2016), as revised (May 24, 2016), TransUnion moved to dismiss this case on the grounds that Clark and the proposed class lack standing. In its December 2016 Opinion, the Court denied TransUnion's motion, explicitly rejecting TransUnion's contention that each class member would need to prove individualized injury in fact based on harm suffered beyond the violation of § 1681g(a)(2) itself. Clark, 2016 WL 7197391, at *11; see also Thomas v. FTS USA, LLC, No. 3:13cv825,2016 WL 3653878 (E.D. Va. June 30, 2016). The Court explained:

Clark, 2016 WL 7197391, at *9. In a footnote, the Court continued: "Mere factual differences. . . do not end the analysis. The finding of injury in fact in these decisions rests in large part on the consumer's inability to monitor his or her file for falsity when not provided the relevant information." Id. at *10 n.20 (citing Patel v. TransUnion, LLC, No. 14cv00522-LB, 2016 WL 6143191, at *4 (N.D. Cal. Oct. 21, 2016) ("[A] consumer cannot monitor [his or] her file for falsity if [he or] she is not given the relevant information. That impediment, that non-disclosure, is thus a real injury. At the very least, preventing a consumer from monitoring [his or] her file presents a `risk of real harm' of exactly the type that [the] FCRA seeks to prevent (i.e., the dissemination of incorrect information); and this risk can itself `satisfy the requirement of concreteness.'")).

When highlighting the remedial purpose of the FCRA, the Court noted that "Congress intended that the FCRA be construed to promote the credit industry's responsible dissemination of accurate and relevant information and to maintain the confidentiality of consumer reports." Id. at * 8 (citing Thomas, 2016 WL 3653878, at *7-8). Moreover, "Congress sought `to establish [] the right of a consumer to be informed of investigations into his [or her] personal life.'" Id. (citing Thomas, 2016 WL 3653878, at *8). With respect to disclosure provisions in particular, including § 1681g(a), the Court concluded that the FCRA "promotes consumer oversight of compliance . . . by informing consumers of the source of the reported information, thereby advancing the broader purposes of `fair and accurate credit reporting.'" Id. (quoting Gillespie v. Equifax Info. Servs., LLC, 484 F.3d 938,941 (7th Cir. 2007)). Looking to these purposes of the FCRA, the Court ultimately reasoned that the "failure to reveal source information reflects the type of harm, or injury in fact, that Spokeo recognizes as `concrete' and `particularized.'" Id. at *9.

Despite this Court's December 2016 Opinion, TransUnion relentlessly pursues its preferred interpretation of Spokeo's effect on defining a "concrete" injury. (See, e.g., Opp'n Mot. Strike 10, ECF No. 117 Spokeo clarified that a plaintiff does not satisfy the `injury-in-fact requirement by merely alleging a violation of a statutory right, but must demonstrate a concrete injury even in the context of a statutory violation." (citations omitted)).) As discussed below, to the extent TransUnion proffers more recent cases that have interpreted Spokeo differently, none persuade the Court to reconsider its December findings.

In re Michaels Stores. Inc.

For instance, TransUnion suggests that In re Michaels Stores, Inc., No. 2:15cv2547, 2017 WL 354023 (D.N.J. Jan. 24,2016), concluded that bare procedural violations of the FCRA do not satisfy the injury-in-fact requirement of a standing analysis. But the Michaels Stores decision provides no analysis on the legislative history of the FCRA, or the purpose of the statutory provision at issue. It thus ignores Spokeo's requirement to consider the judgment of Congress when evaluating whether an intangible injury satisfies the "concreteness" requirement. Spokeo, 136 S. Ct. at 1549. Spokeo recognized that Congress "`has the power to define injuries and articulate chains of causation that will give rise to a case or controversy where none existed before.'" Id. (quotation omitted). But Michaels Stores, without elaboration, unpersuasively dismisses Spokeo's guidance in conclusory fashion. 2017 WL 354023, at *7. And Michaels Stores differs factually in an important way: those plaintiffs "concede[d] that they d[id] not plead any concrete harm." Id. at *3. Perhaps in view of this pleading error, the Michaels Stores court permitted plaintiffs leave to file amended complaints. Id. at * 12.

Cruper-Weinmann v. Paris Baeuette America. Inc.

Relying on Cruper-Weinmann v. Paris Baguette America, Inc., No. 13 CIV. 7013, 2017 WL 398657, at *3 (S.D.N.Y. Jan. 30, 2017), TransUnion next contends that Spokeo created a two-part test to establish concrete injury: (1) that the case involves a specific right created by "Congress . . . to protect a concrete interest of the plaintiff'; and, (2) that "the alleged violation of [a] right presented a material risk of harm to that concrete interest." (Opp'n Mot. Strike 10.) However, TransUnion cites no Fourth Circuit cases performing such a two-step inquiry, and the Court sees none. But even assuming that Cruper-Weinmann*s test for informational injury was sound, Clark likely would satisfy it. This Court has recognized that Clark, and anyone not notified that LexisNexis was a source of public records information, has suffered the violation of a right created by Congress. See Clark, 2016 WL 7197391, at *11. The violation of that right creates "a material risk that LexisNexis could . . . report inaccurate information to others in the future." Id. (emphasis added).

In Cruper-Weinmann, on the other hand, the plaintiff could not assert standing under the Fair and Accurate Credit Transactions Act (the "FACTA") because she did not suffer a risk of harm after a restaurant printed a receipt that displayed the expiration date of her credit card. The court explained:

Cruper-Weinmann, 2017 WL 398657, at *1. As such, the statutory violation in Cruper-Weinmann, unlike TransUnion's alleged violations of § 1681g(a)(2), resulted in no risk of harm to the plaintiff. Accordingly, even were TransUnion's standing argument before this Court properly, it likely would fail.

TransUnion also had sought to strike class certification in its Motion to Dismiss. In the December 2016 Opinion, the Court rejected that challenge as untimely because class certification would be "more appropriately [brought] on the more complete record than the parties' briefing" then provided. Clark, 2016 WL 7197391, at *5. Although discovery disputes continue to plague this litigation,5 the Court now considers the Motion for Class Certification.6

B. Factual Background

As noted in the December 2016 Opinion, although the Motion for Class Certification pertains exclusively to Clark's ability to certify the class and advance the Class Claim, Clark's five individual counts provide context to the entire action. Accordingly, the Court outlines the Class Claim, Clark's individual claims, and the facts framing all allegations below.

1. The Named Plaintiffs Individual Claims (Counts II through VI)

Clark alleges that on August 7,2014, TransUnion provided to her a copy of her credit file that incorrectly listed two civil judgments entered against her. TransUnion listed the sources of the two judgments as "Henrico District Court" and "Virginia Federal Court," respectively. (First Am. Class Compl. ¶ 27.) Clark contends that another source of the judgments was LexisNexis, the third-party vendor that retrieved the data.

Quik Cash allegedly entered one of the judgments against Clark in November 2008 in the amount of $575, even though that judgment had been appealed and dismissed. Clark submitted multiple demand letters requesting that TransUnion correct its error. TransUnion, however, purportedly failed to conduct a "timely and reasonable reinvestigation" and continued to report the Quik Cash judgment as unpaid. (Id. ¶ 35.)

These events, according to Clark, give rise to five individual claims. Count II, the "Reasonable Procedure Claim," proceeds under 15 U.S.C. § 1681e(b).7 Count III, the "Reasonable Reinvestigation Claim," invokes 15 U.S.C. § 1681i(a)(l).8 Count Four, the "Failure to Send Furnisher all Relevant Information Claim," cites 15 U.S.C. § 1681i(a)(2).9 Count Five, the "Failure to Review Consumer Communication Claim" relies upon 15 U.S.C. § 1681i(a)(4).10 Finally, Count Six, the "Failure to Delete Claim," proceeds under 15 U.S.C. § 1681(a)(5).11 For each of these five individual claims, Clark seeks actual damages, statutory damages, punitive damages, costs, and attorneys' fees under §§ 1681n and 1681o.12

2. The Class Claim (Count I)

In the Class Claim, Clark alleges that TransUnion violated § 1681g(a)(2) by failing to convey on her credit file that LexisNexis was a source of the judgment information. To advance the claims of similarly situated individuals, Clark proposes to certify a class as follows:

(First Am. Class Compl. ¶ 62.) Clark seeks statutory and punitive damages in the amount of not less than $100 and not more than $1,000 per violation per class member, as set forth in 15 U.S.C. § 1681n(a).

II. Analysis

Clark seeks to certify a class comprised of individuals who received credit reports from TransUnion "that did not include any reference to its public records vendor as the source of public records information within the consumer's file disclosure." (First Am. Class Compl. ¶ 62.) At the heart of the Class Claim rests the straightforward allegation that TransUnion has a systemic procedure of willfully omitting its source of public records information in its consumer reports. In spite of this direct theory of liability, TransUnion opposes certification.

TransUnion's opposition to the Motion for Class Certification repeatedly highlights the factual differences regarding the purported inaccuracies on the class members' consumer reports. TransUnion proffers this argument in several ways, ultimately contending that these disparities necessarily mean that the class members suffered different injuries. According to TransUnion, such dissimilarities cannot survive the rigorous analysis this Court must undertake before certifying a class under Federal Rule of Civil Procedure 23.13 In so arguing, TransUnion either continues to dispute this Court's ruling on standing14 or it erroneously adds an element of accuracy to § 1681g(a)(2)'s plain language. Both of TransUnion's arguments founder. The Class Claim seeks redress not for inaccurate public records information, but for TransUnion's failure to disclose the sources of public records information on the class members' consumer reports—irrespective of the accuracy of the information those sources provide.

For the reasons stated below, Clark readily meets the Rule 23 requirements. The Court will certify the class.

A. Standard for Class Certification

Clark, as plaintiff, bears the burden of proving all requirements of Rule 23. Lienhart Dryvit Sys., Inc., 255 F.3d 138, 146 (4th Cir. 2001). First, her proposed class must satisfy the four requirements of Federal Rule of Civil Procedure 23(a).15 Those requirements are that: (1) the class is so numerous that joinder of all members is impracticable; (2) there are questions of law or fact common to the class; (3) the class representative's claims or defenses are typical of those of the class; and, (4) the class representative will fairly and adequately represent the interests of the class. See Broussard v. Meineke Disc. Muffler Shops, Inc., 155 F.3d 331, 337 (4th Cir. 1998).

Second, Clark's proposed class must align with at least one of the types of class actions delineated in Federal Rule of Civil Procedure 23(b),16 and meet the corresponding prerequisites for certification. Here, Clark moves for certification under Rule 23(b)(3). A court may certify a class under Rule 23(b)(3) when it finds that: (1) questions of law or fact common to the members of the class predominate over any questions affecting only individual members; and, (2) a class action is superior to other available methods for the fair and efficient adjudication of the controversy.

As the United States Court of Appeals for the Fourth Circuit has explained, courts need not "accept plaintiffs' pleadings when assessing whether a class should be certified." Gariety Grant Thornton, LLP, 368 F.3d 356, 365 (4th Cir. 2004). Rather, "the district court must take a `close look' at the facts relevant to the certification question and, if necessary, make specific findings on the propriety of certification." Thorn v. Jefferson-Pilot Life Ins. Co., 445 F.3d 311, 319 (4th Cir. 2006) (quoting Gariety, 368 F.3d at 365). "Such findings can be necessary even if the issues tend to overlap into the merits of the underlying case," but "[t]he likelihood of the plaintiffs' success on the merits . . . is not relevant to the issue of whether certification is proper." Id (internal citations omitted).

The Supreme Court recently elaborated on a district court's ability to make factual determinations at the class certification stage in Wal-Mart Stores, Inc. v. Dukes, 541 U.S. 338 (2011). In Dukes, the Supreme Court explained:

541 U.S. at 350 (quoting Gen. Tel. Co. ofSw. v. Falcon, 457 U.S. 147,160-61 (1982) (emphasis in original)). "Frequently that `rigorous analysis' will entail some overlap with the merits of the plaintiff's underlying claim. That cannot be helped."17 Mat 351.

B. Clark Satisfies the Requirements of Rule 23

As delineated above, Clark must satisfy the numerous requirements of Rule 23 before this Court may certify the proposed class. Upon review, the Court determines that Clark has done so. The Court will address the requirements of Rule 23(a) and Rule 23(b) seriatim.

1. Clark Satisfies the Four Requirements of Rule 23(a)

Clark's class satisfies the four requirements of Rule 23(a): (1) numerosity of the class makes joinder of all members impracticable; (2) there are questions of law or fact common to the class; (3) Clark's claims typify those of the class; and, (4) Clark will fairly and adequately represent the interests of the class. See Broussard, 155 F.3d at 337.

a. Clark's Class is So Numerous That Joinder of All Members is Impracticable

Appropriately, TransUnion does not oppose Clark's assertion that numerosity makes joinder of all class members impracticable. Clark easily satisfies this requirement. Although no there is no minimum number of potential class members needed to fulfill the numerosity requirement, see Holsey v. Armour & Co., 743 F.2d 199, 217 (4th Cir. 1984), joinder usually becomes impracticable where the class exceeds 40 members, see Kennedy v. Va. Polytechnic Inst. & State Univ., No. 7-08cv00579, 2010 WL 3743642, at *3 (W.D. Va. Sept. 23, 2010).18

The Court must also determine whether it can ascertain Clark's class. See Soutter Equifax Info. Servs., LLC, 307 F.R.D. 183, 196 (E.D. Va. 2015) ("In order to certify a class under Rule 23, a court must be able to readily identify the class members in reference to objective criteria. Although the plaintiff need not be able to identify every class member at the time of certification, the plaintiff must demonstrate that class members will be identifiable without extensive and individualized fact-finding or mini-trials." (internal quotation marks and citations omitted)). TransUnion has admitted in discovery that it has the ability "to determine from [its] records the identity and number of disclosures [it] sent to consumers" with "an address in the Fourth Circuit and an item in the`Public Records' section of their report." (Responses of TransUnion to Clark's First Set of Requests for Admission No. 15, ECF No. 66-2.)20 In light of TransUnion's own admission, the Court finds that Clark can ascertain and identify the class.21

b. Questions of Law or Fact Are Common to the Class

Two questions underlie the proposed class action: (1) whether TransUnion's uniform policy to withhold the disclosure of LexisNexis as its source of public records information violated § 1681g(a)(2); and, (2) whether TransUnion acted willfully in withholding this information. These questions, common to the class, satisfy Rule 23(a)(2).

Rule 23(a)(2) requires that class members' claims involve common questions of law or fact. Fed. R. Civ. P. 23(a)(2). "The commonality requirement focuses on the claims of the class as a whole, and whether they turn on questions of law applicable in the same manner to each member of the class.'" Soutter, 307 F.R.D. at 199 (quoting Califano v. Yamasaki, 442 U.S. 682, 701 (1979)). "To satisfy this requirement, there need be only a single issue common to the class." Id. (citing Cent. Wesleyan Coll. v. W.R. Grace & Co., 143 F.R.D. 628, 636 (D.S.C. 1992), aff'd6 F.3d 177 (4th Cir. 1993)). Clark, however, cannot merely allege that the class members "have all suffered a violation of the same provision of law." Dukes, 564 U.S. at 360. "Commonality requires the plaintiff to demonstrate that the class members have suffered the same injury." Id. That is, the "common contention . . . [must be] of such a nature that it is capable of classwide resolution—which means that determination of its truth or falsity will resolve an issue that is central to the validity of each one of the claims in one stroke." Id.

Clark submits that FCRA cases, and specifically those involving violations of § 1681g(a)(2), have repeatedly been held to satisfy the commonality requirement of Rule 23(a)(2).22 The Court agrees. In spite of such authority, TransUnion contends that "proving the class claim will require a review of every single credit file to determine whether the public records information contained therein was in fact inaccurate" (Opp'n Mot. Class Certification 18 (emphasis added).) TransUnion argues that "a consumer who received a credit file with accurate public record information has no need to seek correction, and therefore could not have been affected at all by not being told the details of how TransUnion retrieved the data." (Id. (emphasis added).) By making this argument, TransUnion again appears to: (1) conflate standing, which this Court has already decided, with the merits; or, (2) add an accuracy element to the statutory language of § 1681g(a)(2). Both arguments fail.

Section 1681g(a)(2) requires TransUnion to "clearly and accurately disclose to the consumer . . . [t]he sources of information" found in the consumer's credit report. 15 U.S.C. § 1681g(a)(2); see also Dreher v. Experian Info. Sols., Inc., 71 F.Supp.3d 572, 579 (E.D. Va. 2014) ("Dreher IF). As explained in Dreher II,

c. Clark's Claim Is Typical of Those of the Class

Clark contends that she satisfies typicality because, by alleging a violation of § 1681g(a)(2), proving her claim will necessarily advance the claims of all class members. The Court agrees.

For a class representative to satisfy typicality, he or she "must be part of the class and possess the same interest and suffer the same injury as the class members." Dieter v. Microsoft Corp., 436 F.3d 461,466 (4th Cir. 2006); see also Soutter, 307 F.R.D. at 208 ("[T]he typicality prerequisite focuses on the general similarity of the named representative's legal and remedial theories to those of the proposed class."). As explained by the Fourth Circuit in Dieter:

436 F.3d at 466-67. In short, "[t]he essence of the typicality requirement is captured by the notion that `as goes the claim of the named plaintiff, so go the claims of the class.'" Id. at 466 (quoting Broussard, 155 F.3d at 340).

Here, Clark's interests align with those of the class, and she alleges to have suffered the same injury. Clark's § 1681g(a)(2) claim arises from TransUnion's failure to disclose the source of information reported on her consumer report. And the Class Claim arises from the same omission. "Because there are no factual differences between claims and the members all raise the same legal issue as [Clark], there are no factual or legal differences between the class members' claims and [Clark's] claims." Milbourne v. JRK Residential America, LLC, No. 3:12cv861, 2014 WL 5529731, at *7 (E.D. Va. Oct. 31,2014) ("Milbourne 7").

Disagreeing with this straightforward analysis, TransUnion contends that Clark cannot satisfy the typicality requirement because her claim involves experiences unique to Clark, who "`is subject to unique defenses which threaten to become the focus of the litigation.'" (Opp'n Mot. Class Certification 18 (quoting Shiring v. Tier Techs., Inc., 244 F.R.D. 307, 313 (E.D. Va 2007).) TransUnion specifically argues that Clark "is an atypical and inadequate class representative because: (i) the facts surrounding her allegations are unique; (ii) her claims are subject to unique defenses; and[J (iii) the conditions that led to this lawsuit were created by her counsel, who still represents her in this matter."26 (Id.) TransUnion's argument does not affect the Court's typicality analysis.

First, TransUnion opposes typicality on the incorrect presumption that Clark's § 1681g(a)(2) claim depends on facts entirely unique to her. While TransUnion correctly identifies that Clark's case had a judgment that was appealed and dismissed, but remained on her credit file, those "unique" facts have no bearing on her § 1681g(a)(2) claim (i.e., the Class Claim).27 Indeed, the Class Claim involves only whether TransUnion disclosed the "sources of information," an omission that satisfies "the notion that `as goes the claim of the named plaintiff, so go the claims of the class.'" Deiter, 436 F.3d at 466 (quoting Broussard, 155 F.3d at 340).

Second, TransUnion argues that Clark's case is "unique" because it may assert a statuteof-limitations defense against Clark in particular. TransUnion relies on 15 U.S.C. § 1681p, which states:

15 U.S.C. § 1681p. TransUnion posits that any alleged violation serving as the basis for its liability under § 1681g(a)(2) occurred prior to May 20, 2009, when Clark first disputed the Quik Cash Judgment on her TransUnion consumer report. (Opp'n Mot. Class Certification 22 (citation omitted).) TransUnion argues that, because it failed to disclose LexisNexis as the source of information regarding Clark's Quik Cash Judgment at that time, the violation occurred then—more than five years before Clark filed suit.

In reply, Clark argues that no such defense exists because "[a] consumer need not allege (or prove) either that the [consumer reporting agency] furnished an inaccurate credit report or that [the consumer] made a § 1681i(a) dispute before being afforded the right to see what is actually in [his or] her credit file." (PL's Reply 17, ECF No. 104.) In support of her position, Clark cites Yarish v. Downey Fin. Corp., No. 3:08cv380,2009 WL 1208178 (E.D. Va. Apr. 28, 2009),28 which pertains only to the two-year statute of limitations in § 1681p(l).

The five-year statute of repose in § 1681p(2), on the other hand, includes no discovery component. Section 1681p(2) bars any claim arising out of a violation that occurred more than five years before a plaintiff filed suit. See Milbourne v. JRK Residential Am., LLC, No. 3:12cv861, 2016 WL 1071569, at *5 (E.D. Va. Mar. 15,2016) ("Milbourne III") (referring to § 1681p(2) as "a five-year absolute statute of repose").

Regardless, the Court cannot find that the five-year statute of repose has run as to Clark's § 1681g(a)(2) claim. Trans Union did not rectify its failure to disclose LexisNexis immediately after the alleged May 2009 violation. In fact, the 2014 consumer credit report provided to Clark continued to state that TransUnion obtained the records only from the courthouses that maintained the records: "Virginia Federal Court" and "Henrico District Court." Even if TransUnion violated § 1681g(a)(2) as early as 2009, it violated the statute again in 2014. Thus, even if § 1681p bars a claim arising out of TransUnion's failure to disclose the source of information on Clark's consumer report in 2009, Clark's claim can rest on the 2014 violation or any violation within five years of the date Clark brought this case.29 Accordingly, Clark satisfies the typicality requirement of Rule 23(a)(3).

d. Clark Will Fairly and Adequately Represent the Interests of the Class

The final requirement of Rule 23(a) requires that the "representative parties will fairly and adequately protect the interests of the class." Fed. R. Civ. P. 23(a)(4). Rule 23(a)(4) "is met if the named plaintiff has interests common with, and not antagonistic to, the [c] lass's interests; and . . . the plaintiffs attorney is qualified, experienced and generally able to conduct the litigation." Milbourne I, 2014 WL 5529731, at *8 (internal citations and quotations omitted). "[T]he adequacy inquiry itself focuses on conflicts of interests." Soutter, 307 F.R.D. at 213. Clark meets the adequacy requirement.

First, Clark has no interests antagonistic to the class's interests. Clark and the class share the identical interest of establishing Transition's liability based on the same questions of law and fact. TransUnion does not contend otherwise, and the record demonstrates no conflicts of interest.

Second, the record does not demonstrate that either Clark or her attorneys are not suited to represent the class. This Court has repeatedly found that Clark's counsel is qualified to conduct such litigation. See, e.g., Manuel v. Wells Fargo Bank, Nat'l Ass'n, No. 3:14cv238, 2016 WL 1070819, at *3 (E.D. Va. Mar. 15,2016) ("[T]his Court would have difficulty overstating Class Counsel's experience in the area of FCRA class action litigation."); Thomas v. FTS USA, LLC, 312 F.R.D. 407,420 (E.D. Va. 2016) ("the Court finds that Thomas'[s] counsel is qualified, experienced, and able to conduct this litigation so as to fully and adequately represent both classes. Counsel is experienced in class action work, as well as consumer protection issues, and has been approved by this Court and others as class counsel in numerous cases around the country."); Dreher I, 2014 WL 2800766, at *2 ("Dreher's counsel is wellexperienced in the arena of FCRA class action litigation."). This Court echoes the sentiments previously stated about Clark's counsel because they pertain here with equal vigor.30

The Court further rejects TransUnion's argument that Clark should not represent the class simply because her knowledge of the case does not rise to that of her counsel's. See Gunnells Healthplan Servs., Inc., 348 F.3d 417,430 (4th Cir. 2003) ("It is hornbook law . . . that `[i]n a complex lawsuit, such as one in which the defendant's liability can be established only after a great deal of investigation and discovery by counsel against a backdrop of legal knowledge, the representative need not have extensive knowledge of the facts of the case in order to be an adequate representative."); see also Flores v. Anjost Corp., 284 F.R.D. 112, 129 (S.D.N.Y 2012) ("`Knowledge of all the intricacies of the litigation is not required and several courts have found that general knowledge of what is involved is sufficient.' While Rule 23 requires `adequate personal knowledge of the essential facts of the case,' plaintiffs are entitled to rely on their counsel for the legal underpinning of their claims." (citations omitted)); Barr v. Harrah's Entm % Inc., 242 F.R.D. 287,295 (D.N.J. 2007) ("A class representative need only possess `a minimal degree of knowledge necessary to meet the adequacy standard."). Clark's counsel represents that Clark has participated in discovery and has asked appropriate questions. Clark's deposition testimony demonstrates that she has sufficient general knowledge of the case. (Clark Dep. 162:18-25 (suggesting that her responsibilities as class representative include "representing for the whole as one" and "mak[ing] sure everybody is treated fair and equally so they won't have to experience, moving forward, incorrect information being reported"). Accordingly, Clark satisfies the adequacy requirement of Rule 23(a)(4).

2. Clark Satisfies the Predominance and Superiority Requirements of Rule 23(b)

In addition to satisfying the four requirements of Rule 23(a), Clark's proposed class must also align with at least one of the types of class actions delineated in Federal Rule of Civil Procedure 23(b) and meet the corresponding prerequisites for certification. The three types of class actions in Rule 23(b) are as follows:

Fed. R. Civ. P. 23(b).

Here, Clark moves for certification under Rule 23(b)(3). Certification under Rule 23(b)(3) is appropriate where the Court finds that: (1) questions of law or fact common to the members of the class predominate over any questions affecting only individual members; and, (2) a class action is superior to other available methods for the fair and efficient adjudication of the controversy.

a. Questions Common to the Class Predominate Over Questions Affecting Only Individual Members

Clark satisfies the predominance requirement of Rule 23(b)(3). Under Rule 23(b)(3), questions common to the class "must predominate over any questions affecting only individual members." Amchem Prods., Inc. v. Windsor, 521 U.S. 591, 615 (1997). Whether common questions predominate over individual questions "is a separate inquiry, distinct from the requirements found in Rule 23(a)." Ealy v. Pinkerton Gov't Servs., 514 F. App'x 299, 305 (4th Cir. 2013) (citing Dukes, 131 S. Ct. at 2556). This requirement is "even more demanding than Rule 23(a)," Comcast, 133 S. Ct. at 1432, and "tests whether proposed classes are sufficiently cohesive to warrant adjudication by representation," Amchem, 521 U.S. at 623.

"Rule 23(b)(3)'s commonality-predominance test is qualitative rather than quantitative." Stillmockv. Weis Markets, Inc., 385 F. App'x 267,272 (4th Cir. 2010) (citing Gunnells, 348 F. 3d at 429). If the "qualitatively overarching issue" in the litigation is common, a class may be certified notwithstanding the need to resolve individualized issues. See Ealy, 514 F. App'x at 305 ("Indeed, common issues of liability may still predominate even when some individualized inquiry is required.").

Clark satisfies the predominance requirement because Clark's and the class members' claims encompass the same essential factual and legal issues. The dominant issue before the Court is the ultimate question of liability: whether TransUnion willfully failed to disclose as its source the third-party public records vendor, LexisNexis, in violation of § 1681g(a)(2). This alone, as the qualitatively overarching issue of this case, satisfies the predominance requirement and outweighs any issues particular to individual class members. As explained in Stillmock:

385 F. App'x at 273.31 Accordingly, Clark satisfies the predominance requirement of Rule 23(b)(3).

b. A Class Action is Superior to Other Available Methods for Fairly and Efficiently Adjudicating This Lawsuit

Clark satisfies the superiority requirement. Superiority requires that litigation by means of a class action be "superior to other available methods for fairly and efficiently adjudicating the controversy." Fed. R. Civ. P. 23(b)(3). Superiority "`depends greatly on the circumstances surrounding each case,'" and "`[t]he rule requires the court to find that the objectives of the class-action procedure really will be achieved.'" Stillmock, 385 F. App'x at 274 (internal citation omitted). When making a "determination of whether the class action device is superior to other methods available to the court for a fair and efficient adjudication of the controversy . . . [the court should] not contemplate the possibility that no action at all might be superior to a class action." Brown v. Cameron-Brown Co., 92 F.R.D. 32,49 (E.D. Va. 1981). In determining whether the class action mechanism is truly superior, the court should consider "the class members' interest in individually controlling the prosecution or defense of separate actions; the extent and nature of any litigation concerning the controversy already begun by or against class members; the desirability or undesirability of concentrating the litigation of the claims in the particular forum; and[J the likely difficulties in managing the class action." Fed. R. Civ. P. 23(b)(3)(AHD).

TransUnion again contends that factual differences preclude certification, claiming that the supposed individualized claims would make managing the class action ineffective. (See Opp'n Mot. Class Certification 30 ("[T]here are incredible complexities in managing litigation on behalf of the class consisting of persons who each, individually, would need to tender proof of specific, concrete injury under Section 168 lh as a result of TransUnion's manner of disclosing public record sources.").) The Court has already rejected that argument, finding that resolving the Class Claim will not require individualized inquiries concerning any inaccuracies in the class members' consumer reports. TransUnion's objection to superiority aside, Clark satisfies the requirement for two principal reasons. First, a class action could provide redress to claimants who, as a result of the technical nature of TransUnion's violation, might not otherwise know the existence of their respective claims. See Manuel, 2015 WL 4994549, at *18; Soutter, 307 F.R.D. at 218 ("`[T]here is a strong presumption in favor of a finding of superiority,' where, as here, `the alternative to a class action is likely to be no action at all for the majority of class members.'" (citation omitted)); Dreher I, 2014 WL 2800766, at *5 (finding superiority where "the class members do not have a strong interest in individually prosecuting the case").

Second, a class action gives claimants incentive to pursue claims that otherwise would not be worth pursing in light of the insignificant damages that could be recovered. See Stillmock, 385 F. App'x at 274 ("[T]he low amount of statutory damages available means no big punitive damages award on the horizon, thus making an individual action unattractive from a plaintiffs perspective. Second, there is no reasoned basis to conclude that the fact that an individual plaintiff can recover attorney's fees in addition to statutory damages of up to $1,000 will result in enforcement of [the] FCRA by individual actions of a scale comparable to the potential enforcement by way of class action."); see also Soutter, 307 F.R.D. at 218 (following Stillmock to find superiority where statutory damage provisions in the FCRA cannot support any meaningful number of individual suits); Dreher I, 2014 WL 2800766, at *5. Accordingly, Clark satisfies the superiority requirement of Rule 23(b)(3).

III. Conclusion

For the foregoing reasons, the Court finds that Clark meets the requirements of Federal Rule of Civil Procedure 23. The Court will grant the Motion for Class Certification.

An appropriate Order shall issue.