Mazza v. Verizon Washington, Dc, Inc., 852 F. Supp. 2d 28

Mazza sues Verizon entities (VZDC, Verizon Wireless) and AFNI for FCRA and FDCPA violations and two common law claims.
Mazza terminated bundled services with Verizon in 2007 and allegedly received a final bill and disputed charges.
AFNI allegedly pursued collection and reported to credit bureaus; Mazza alleges settlement offers and investigations were promised but not resolved.
Mazza alleges several rounds of inquiries to all defendants seeking reversal of negative credit reporting and correct remittance records.
The court addresses whether Mazza states claims under FCRA 1681s-2(a) and 1681s-2(b), FDCPA, and whether personal jurisdiction over Verizon Communications exists.
The court grants in part and denies in part the defendants’ motion to dismiss, dismissing some claims without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
FCRA private right of action under 1681s-2(a)	Mazza pleads furnishers violated 1681s-2(a).	1681s-2(a) provides no private right of action.	1681s-2(a) private right not available; move forward on 1681s-2(b).
FCRA private right under 1681s-2(b)	Mazza notified CRAs and seeks investigation by furnishers.	Plaintiff failed to show CRA notice to furnishers triggered duties.	Court allows 1681s-2(b) claim to proceed; denial of dismissal as to 1681s-2(b).
FDCPA timeliness and applicability to VZDC	FDCPA violations occurred as late as 2010; timely within one year.	VZDC collection acts not subject to FDCPA as creditor.	FDCPA claims not time-barred; VZDC's actions improper under FDCPA are dismissed per creditor exemption; AFNI claims survive.
FDCPA false or deceptive representations (1692e) against AFNI	AFNI made false or deceptive collection representations.	No specific false statements identified; cannot support 1692e claim.	1692d claims survive against AFNI; 1692e claim not established due to lack of specific misrepresentation.
Personal jurisdiction over Verizon Communications	Verizon Communications has broad corporate links to VZDC/Verizon Wireless; alter ego theory.	No minimum contacts; separate corporate entities; no alter ego shown.	No specific or general jurisdiction over Verizon Communications; claims dismissed as to Verizon Communications.

Crane v. N.Y. Zoological Soc’y, 894 F.2d 454 (D.C. Cir. 1990) (personal jurisdiction prima facie standard; weigh affidavits)
First Chi. Int’l v. United Exch. Co., Ltd., 836 F.2d 1375 (D.C. Cir. 1988) (prima facie jurisdiction; pleadings + affidavits)
Second Amendment Found. v. U.S. Conference of Mayors, 274 F.3d 521 (D.C. Cir. 2001) (jurisdictional pleading standards)
Urban Inst. v. FINCON Servs., 681 F. Supp. 2d 41 (D.D.C. 2010) (transfer of jurisdictional analysis to pleadings)
Mwani v. Bin Laden, 417 F.3d 1 (D.C. Cir. 2005) (jurisdictional facts may be factual determinations)
Chiang v. Verizon New Eng., Inc., 595 F.3d 26 (1st Cir. 2010) (private right of action under 1681s-2(b))
Gorman v. Wolpoff & Abramson, LLP, 584 F.3d 114 (D.C. Cir. 2009) (FCRA furnishers duties and private actions)
Saunders v. Branch Banking & Trust Co., 526 F.3d 142 (4th Cir. 2008) (FCRA 1681s-2(b) private right discussions)
Westra v. Credit Control of Pinellas, 409 F.3d 825 (7th Cir. 2005) (FDCPA 1692d,e standard; least sophisticated debtor)
Maguire v. Citicorp Retail Servs., 147 F.3d 232 (2d Cir. 1998) (least sophisticated consumer standard)
Goodyear Dunlop Tires Operations v. Brown, 131 S. Ct. 2846 (S. Ct. 2011) (general jurisdiction standard)
International Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (minimum contacts due process)