Information Solutions, Inc., 155 F.Supp.2d 356, 361 (E.D.Pa.2001) (the plain language of § 1681t(b)(l)(F) clearly eliminated all state causes of action against furnishers of information, not just ones that stem from statutes that relate specifically to credit reporting). Second Approach — Other district courts have determined that § 1681t(b)(l)(F) does not preempt common law tort claims, and such claims may be brought but have reached this conclusion by two different avenues. The first group contends that 1681t(b)(l)(F) applies to state statutes only, and that § 1681h(e) applies to common law torts. A discussion of this rationale is set out in McCloud v. Homeside Lending, 309 F.Supp.2d 1335, 1341 (N.D.Ala.2004); and Jeffery v. Trans Union, LLC, 273 F.Supp.2d 725, 726-28 (E.D.Va.2003) (<HOLDING>). The second group adheres to the rationale
holding that while the fourteenth amendment is directed against state action and not private action the state action requirement is met in a civil action where state law is applied whether by statute or common law holding that the fourteenth amendment only applies to state action holding that  1681he not  1681tblf applies to the defamation action so if a plaintiff pleads malice or willful intent to injure the action for violation of a state statute is not preempted holding that an action for consequential damages to property whether the action is brought in contract or in tort is an action for injury to property within the threeyear statute of limitations holding that fourteenth amendment only applies to state action