of conducting an employee background investigation, but was hired to provide a variety of legal support to DHA Group. Courts have long recognized that an attorney is the agent of his client. See Hartman v. Lisle Park District, 158 F.Supp.2d 869, 876 (N.D.Ill.2001) (citing Steffes v. Stepan Co., 144 F.3d 1070, 1075 (7th Cir.1998)); Shenandoah Associates Ltd v. Tirana, 322 F.Supp.2d 6, 10 (D.D.C.2004) (quoting Virginia Electric and Power Co. v. Bowers, 181 Va. 542, 25 S.E.2d 361 (1943)). Specifically, in the context of the FCRA, several courts have explained that an attorney who conducts an investigation on behalf of an employer-client is not a “third party” in the same way that a credit bureau or detective agency would be. Id.; cf. Norman v. Lyons, 2013 WL 655058, *3 (N.D.Tex.2013) (<HOLDING>). As the District Court for the Northern
holding that nothing in the legislative history of the pennsylvania consumer fraud act suggests that the legislature ever intended statutory language directed against consumer fraud to do away with the traditional elements of reliance and causation and accordingly in order to maintain a class action suit under the pennsylvania consumer fraud act a plaintiff must allege reliance holding that a garnishment proceeding is an action against the consumer holding commercial franchises are not covered by new jersey consumer fraud act because they are businesses and not consumer goods holding that the punitive provisions of the delaware consumer fraud act were not applicable to attorney conduct occurring within the practice of law given the state supreme courts inherent constitutional and statutory authority to discipline members of the state bar noting the lack of consensus in different jurisdictions as to the applicability of state consumer fraud acts to attorney conduct holding that a consumer reporting agency which gives a consumer report to the attorney representing the agency is not subject to the fcra because the attorney is not a traditional third party