Plaintiffs pursuing claims under the Fair Credit Reporting Act (“FCRA”) (15 U.S.C. § 1681, et seq.) commonly sue “furnishers” along with the consumer reporting agencies. With some exceptions, a “furnisher” is defined as “an entity that furnishes information relating to consumers to one or more consumer reporting agencies for inclusion in a consumer report”. A frequent scenario involves a plaintiff who alleges that he was the victim of identity theft such that a defaulted account has been inaccurately reported as belonging to him on credit reports. The plaintiff typically alleges that he notified the CRAs as well as the furnisher of the identity theft via a dispute letter demanding removal of the inaccurate reporting.