On October 5, the Northern District of California granted a motion to dismiss a complaint brought under the Fair Credit Reporting Act ("FCRA"), finding that the plaintiffs did not sufficiently plead standing. The case arose out of an alleged failure by the defendant transportation network company ("TNC") to provide clear disclosures that it would obtain its employees' credit and background reports. The defendant TNC moved to dismiss the complaint, arguing that the plaintiffs did not allege an injury in fact sufficient to grant Article III standing under the recent standard prescribed by the Supreme Court in Spokeo, Inc. v. Robins. The court agreed, finding that the plaintiff had not alleged a sufficient injury in fact and granting the motion to dismiss.
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