1681m(d)(l), quoted above, especially subsections (B) and (C), assumes that an unsolicited “written solicitation made to the consumer regarding the transaction” include the firm offer of credit. This reading of the statute is confirmed by the legislative history of § 1681b(c)(l)(B)(i) which indicates Congressional intent that the opt-out provision be included in the first “prescreening or direct marketing solicitation.” The required opt-out language, in turn, presumes that a firm offer of credit has been made. See Sen. Rep. 103-209, at 25-26 (1993) (1993 WL 516162). For similar reasons, the Court finds Defendant’s standing argument, which is based upon the fact that Plaintiff did not call Defendant, to be without merit. See In re Trans Union Corp. Privacy Litigation, 211 F.R.D. at 336 (<HOLDING>). The Court cannot conclude at this stage of
holding that plaintiffs may plead on information and belief if matters are not within their personal knowledge holding that plaintiffs lacked standing to sue holding that plaintiffs who alleged that their own personal credit information was disclosed for an improper purpose established their standing to sue under the fcra holding that rico claims were personal and plaintiffs were therefore entitled to sue on their own because their injuries were distinct from the injuries to creditors in general resulting from the diversion of corporate assets holding that employers have standing to sue