the parties do not argue, and we do not address, whether PCA's pre-FACTA conduct may subject it to penalties under a post-FACTA reading of the FCRA. 6 . Experian suggests that Davis v. Asset Servs., 46 F.Supp.2d 503, 508 (M.D.La.1998), Boothe v. TRW Credit Data, 557 F.Supp. 66, 71 (S.D.N.Y.1982), and Hiemstra v. TRW, Inc., 195 Cal.App.3d 1629, 1634, 241 Cal.Rptr. 564 (Cal.Ct.App.1987) support the contention that blanket certifications will satisfy a credit reporting agency's obligations under § 168 le(a). While these cases hold that credit reporting agencies may rely on blanket cer tifications rather than having to verify credit requests individually, none provides that a blanket certification by itself is sufficient to satisfy the § 1681e inquiry. See, e.g., Davis, 46 F.Supp.2d at 508 (<HOLDING>); Boothe, 557 F.Supp. at 71 (finding no
holding that even if the industry and federal regulations evidenced an inherent danger and the defendant knew or should have realized that the device was or was likely to be dangerous for the use for which it was supplied there was a complete absence of evidence that the defendant had reason to believe that the plaintiff or its employees would not realize the danger holding that the government must prove the defendant knew of the features of the firearm that brought it within the scope of the act holding that the defendant lacked sufficient contacts with the forum state because there was no evidence the defendant knew where the product would be sold holding that the defendant complied with the requirements of  1681ea because it obtained a blanket certification and because the plaintiff did not submit any evidence to prove that the defendant knew or should have had reason to know that the subscriber would access the report for an impermissible purpose holding that defendant could not be liable for distributing defamatory statements unless it knew or had reason to know of statements