govinfo:USCOURTS-mdd-1_24-cv-02120-2

1 
IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MARYLAND 
 
SIERRA COOPER, * 
 
Plaintiff, * 
 
v. * Civil Action No. RDB-24-2120 
 
I.Q. DATA INTERNATIONAL, INC., * 
 
Defendant. * 
 
* * * * * * * * * * * * * 
MEMORANDUM OPINION 
Plaintiff Sierra Cooper (“Plaintiff” or “Ms. Cooper”) alleges that Defendant debt 
collection agency I.Q. Data International, Inc. (“Defendant” or “I.Q. Data”) violated state and 
federal statutes by attempting to collect her debt of unpaid rent . See generally (ECF No. 6). 
Between February 2021 and June 2023, Ms. Cooper lived in a residential property owned by 
non-party Hudson Homes Management, LLC (“Hudson Homes”) in Baltimore, Maryland . 
She failed to fully pay her rent and, i n May 2023, the District Court for Baltimore City, 
Maryland entered a consent judgment for possession in favor of Hudson Homes. Ms. Cooper 
asserts that this judgment reduced the amount owed to $8,221.93 because Hudson Homes 
could not collect rent accrued while it was not licensed as required under Baltimore City 
ordinance. ( Id. ¶¶ 8–23.) She moved out of the property in June 2023 without paying any 
portion of the rent owed . (Id. ¶ 13.) Hudson Homes then retained I.Q. Data to collect all 
unpaid rent, including interest, accrued between February 2021 and June 2023. Ms. Cooper 
alleges that I.Q. Data inaccurately reported to consumer reporting agencies that she owed 

 
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Hudson Homes $47,575.00, which damaged her credit score, resulted in the denial of a loan 
she sought in May 2024, and caused her emotional distress. (Id. ¶¶ 22–24.) 
On July 23, 2024, Ms. Cooper initiated this action by filing in this Court a four -Count 
Complaint against I.Q. Data . (ECF No. 1). On October 2, 2024, she filed the operative 
Amended Complaint (ECF No. 6), alleging that I.Q. Data’s debt collection efforts violated (1) 
the Maryland Consumer Debt Collection Act (“MCDCA”), MD. CODE ANN., COM. LAW § 14-
201 et seq. (Count I); (2) the Maryland Consumer Protection Act (“MCPA”), MD. CODE ANN., 
COM. LAW § 13-101 et seq. (Count II); (3) the federal Fair Credit Reporting Act (“FCRA”), 15 
U.S.C. § 1681s-2(a), (b) based on failure to investigate (Count III); and (4) the federal Fair 
Debt Collection Practices Act (“FDCPA”), 15 U.S.C. § 1692e(2)(A) (Count IV).1 This Court 
denied Defendant’s Motion to Dismiss, see (ECF Nos. 10, 11), and the case proceed through 
discovery, see (ECF No. 30). I.Q. Data has filed a Motion for Summary Judgment (ECF No. 
35) (“Defendant’s Motion”), and Ms. Cooper has filed a Cross-Motion for Summary Judgment 
Regarding Liability (ECF No. 36) (“Plaintiff’s Cross-Motion”). I.Q. Data has responded in 
Opposition (ECF No. 37), and Plaintiff has replied (ECF No. 38). On June 2, 2026, this Court 
heard arguments from both parties. As explained on the record and expounded below, 
Defendant’s Motion for Summary Judgment (ECF No. 35) is GRANTED. Plaintiff’s Cross-
Motion for Summary Judgment (ECF No. 36) is DENIED. 
 
1 This Court has federal question jurisdiction of the federal statutory claims in Counts III and IV, see 28 U.S.C. 
§ 1331, and supplemental jurisdiction of the state statutory claims in Counts I and II, see id. § 1367. 

 
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BACKGROUND 
Ms. Cooper’s claims against I.Q. Data arise from her dispute with her former landlord, 
non-party Hudson Homes Management, LLC (“Hudson Homes”), as to rent payments. 
Accordingly, the Court briefly recounts the landlord-tenant relationship between Ms. Cooper 
and Hudson Homes. As clarified at the hearing of June 2, 2026, the facts as to Ms. Cooper’s 
rental relationship with Hudson Homes, the subsequent summary ejectment proceeding, 2 I.Q. 
Data’s collection efforts, and Ms. Cooper’s credit are largely undisputed.3 
I. Landlord-tenant relationship between Ms. Cooper and Hudson 
Homes 
On February 4, 2021, Ms. Cooper and Hudson Homes executed a lease agreement 
under which Ms. Cooper rented a property at 4311 Eldone Road, Baltimore, Maryland 21229, 
for an initial term of February 17, 2021, until February 16, 2022. (ECF No. 35 -3 at 2; ECF 
No. 35-2 at 9–10.) Ms. Cooper asserts that property was not licensed in the manner required 
under Baltimore City ordinance until October 12, 2022. (ECF No. 36-5 at 2; see ECF No. 35-
6 *SEALED* at 40 (showing property was not licensed with Baltimore City Department of 
Housing and Community Development as of June 17, 2022, and had no previous license on 
record)).4 On May 5, 2023, Hudson Homes filed in the District Court for Baltimore City, 
Maryland, a summary ejectment action against Ms. Cooper. (ECF No. 35-4.) In its complaint, 
Hudson Homes represented that it was licensed as a landlord and listed its license number. 
 
2 Summary ejectment proceedings offer an expedited process by which a landlord may obtain a money 
judgment for rent and/or a judgment for possession of the premises against a tenant who has failed to pay rent. 
See Assanah-Carroll, 281 A.3d 72, 93 (Md. 2022). 
3 On the record, the parties noted a dispute as to whether Hudson Homes failed to license the property. 
4 I.Q. Data disputes this assertion and argues that Ms. Cooper’s proffered evidence as to the property’s licensure 
“is unsigned . . . uncertified and unauthenticated.” (ECF No. 37 at 4.) Thus, I.Q. Data asserts that there is no 
evidence as to the property’s licensure in the record before this Court. 

 
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(Id. at 7.) Hudson Homes alleged that Ms. Cooper owed $27,973.44 in unpaid rent for the 
period between March 2021 and February 2023. (Id.) 
On May 26, 2023, the District Court for Baltimore City, Maryland, entered a consent 
judgment for possession in favor of Hudson Homes in the amount of $8,221.93 but stayed 
execution of that judgment until June 9, 2023. See (id. (consent judgment with checkbox 
marked that it is a “[j]udgment in favor of landlord for possession of the premises and costs” 
and checkbox for money judgment and associated amount left blank)). During a brief hearing, 
the parties stated that they had reached “an agreement for consent judgment with a two-week 
stay on the execution of the writ,” and the Court entered “judgment in favor of the landlord 
for possession, for rent, due and unpa id in the amount of $8,22 1.93 by consent ” with 
“[e]xecution . . . stayed until June 9th.” (ECF No. 35-5 at 4–5.) At her deposition in this case, 
Ms. Cooper testified that during th is “court process the judge . . . noted that the rental 
property was not licensed and that the company could not collect on rent for months that they 
did not have a rental license.” (ECF No. 35-2 at 15.) Neither the transcript of the hearing of 
May 26, 2023, nor the consent judgment contain any determination as to licensure. See (ECF 
No. 35-4 at 7; ECF No. 35-5). 
Ms. Cooper testified during her deposition in this case that the judgment included a 
right to redemption by which she would not be evicted if she produced the unpaid rent. (ECF 
No. 35-2 at 12.) Ms. Cooper received rental assistance in the amount of $8,850.00. (ECF No. 
35-6 *SEALED* at 41.) She testified that she attempted to make a payment, but “the rental 
system company” “decided that [it] no longer wanted to take the payment.” (Id.) As a result, 

 
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she never made a payment to Hudson Homes for any portion of the debt amount owed.5 (Id. 
at 13.) Additionally, she stated that she failed to pay rent to Hudson Homes for a substantial 
period due to habitability issues, but she believed the actual amount owed was approximately 
$3,000. (Id. at 11, 19.) Ms. Cooper testified that she physically moved away from the home 
in June 2023. ( Id. at 12.) A Warrant of Restitution – Return of Service was filed in the 
summary ejectment case on June 22, 2023. (ECF No. 35-4 at 3.) 
II. I.Q. Data’s attempts to collect unpaid rent from Ms. Cooper 
A. Initial collection efforts 
On November 21, 2023, Hudson Homes authorized Defendant I.Q. Data to collect 
the unpaid rent balance from Ms. Cooper. (ECF No. 35 -6 *SEALED* ¶ 6.) At that time, 
Hudson Homes provided a Security Deposit Disposition Form , (ECF No. 35 -6 Ex. A 
*SEALED* at 8 –10), and Resident Ledger , (id. *SEALED* at 11–20), reflecting that Ms. 
Cooper owed a principal balance of $46,423.30. (ECF No. 35-6 *SEALED* ¶¶ 7, 8.) Hudson 
Homes also provided a copy of Ms. Cooper’s Lease Agreement. (ECF No. 35-6 *SEALED* 
¶ 9.) On November 22, 2023, I.Q. Data sent Ms. Cooper a notice stating that it sought to 
collect a debt she owe to Hudson Homes. (ECF No. 35 -6 Ex. B *SEALED* at 24.) The 
notice stated that, as of August 15, 2023, Ms. Cooper owed $46,423.30, but, with interest, she 
owed $47,178.79 as of November 22, 2023. (Id. *SEALED*.) 
On December 6, 2023, I.Q. Data called Ms. Cooper regarding the alleged debt that she 
owed to Hudson Homes. (ECF No. 35-6 *SEALED* ¶ 12; ECF No. 35-6 Ex. C *SEALED* 
 
5 As clarified on the record, Ms. Cooper made some payment toward her rent, including a payment of $4,950 
on May 16, 2022, but the $47,575.00 rent debt at issue in this case accounts for that payment. 

 
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at 27.) During this call, Ms. Cooper stated that she “should not have a balance with Hudson 
Homes” and the I.Q. Data representative responded that Hudson Homes sent I.Q. Data a 
balance of approximately $47,000. (ECF No. 35-6 Ex. C *SEALED* at 27.) Ms. Cooper then 
explained that she did not owe that balance because she received a judgment and the judge at 
that time stated that the lease was not valid because Hudson Homes was not a licensed 
landlord for a portion of the period in which it charged her rent. (Id. *SEALED*.) I.Q. Data’s 
representative told Ms. Cooper that the court only determined possession such that she still 
owed the full balance to Hudson Homes. ( Id. *SEALED* at 27 –28.) After Ms. Cooper 
responded that she did not owe the balance, the representative stated that she would mark Ms. 
Cooper’s refusal to pay and “put it on top of [Ms. Cooper’s] credit report.” ( Id. *SEALED* 
at 28.) The call then concluded. (Id. *SEALED*.) Ms. Cooper called I.Q. Data back several 
times the same day to expl ain that Hudson Homes was not entitled to collect rent for the 
period in which it was not licensed as a landlord. ( Id. *SEALED*.) The following day , in 
response to Ms. Cooper’s request, I.Q. Data queued a letter validating the debt, (ECF No. 35-
6 Ex. B *SEALED* at 23), which it mailed to Ms. Cooper on December 21, 2023 , together 
with copies of supporting documents. (ECF No. 35-6 *SEALED* ¶ 14.) 
B. I.Q. Data’s reports of debt to TransUnion, Equifax, and 
Experian 
On January 7, 2024, I.Q. Data began reporting the debt to the consumer reporting 
agencies TransUnion, Equifax, and Experian as disputed. (ECF No. 35 -6 *SEALED* ¶ 15.) 
On January 11, 2024, Ms. Cooper called I.Q. Data and requested that it send proof of the 
balance to her new address. (ECF No. 35 -6 *SEALED* ¶ 16; ECF No. 35 -6 Ex. C 
*SEALED* at 35.) The same day, I.Q. Data queued a letter validating the debt, and that letter 

 
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was mailed to Ms. Cooper’s new address on February 2, 2024. (ECF No. 35 -6 *SEALED* ¶ 
18; ECF No. 35-6 Ex. B *SEALED* at 22.) The January 11, 2024, call was the last telephone 
conversation between I.Q. Data and Ms. Cooper. (ECF No. 35-6 *SEALED* ¶ 17.) 
On March 22, 2024, Ms. Cooper sent TransUnion, Equifax, and Experian identical 
letters disputing the $47,575 debt . (ECF No. 35 -6 Ex. D *SEALED* at 38.) The dispute 
letters stated that (1) Hudson Homes previously admitted in court that it was not a licensed 
landlord and, “[u]nder Article 13 Section 5 -4 of the Baltimore City Code, a landlord renting 
an unlicensed property is not allowed to collect or retain any rent”; and (2) “[u]nder the 
Assanah-Carroll case, Hudson Homes is not allowed to pursue rent from while they were 
unlicensed . . . .” (Id. *SEALED* at 38 (TransUnion), 44 (Experian).) She also explained that 
the district court judgment had reduced the amount owed to $8,221.93. (Id. *SEALED*.) She 
attached to the dispute letters copies of (1) the district court judgment, (2) a Baltimore City 
Rental Licensing Verification Request ; and (3) a Statement reflecting rent assistance in the 
amount of $8,850.00. (Id. *SEALED* at 39–41, 45–47.) The Baltimore City Rental Licensing 
Verification Request was dated June 17, 2022, and reflected that the Baltimore City 
Department of Housing and Community Development “has no record of a rental license 
under Art. 13 subtitle 5 for th[e] property” at 4311 Eldone Road, Baltimore, MD 21229. ( Id. 
*SEALED* at 40, 46.) It did not include a signature. (Id. *SEALED*.) 
C. I.Q. Data’s investigation of disputed debt 
I.Q. Data states that it did not receive any disputes directly from Ms. Cooper, but the 
consumer reporting agencies forwarded I.Q. Data copies of the dispute materials Ms. Cooper 
provided to them. (ECF No. 35 -6 *SEALED* ¶¶ 20, 21.) It states that its “policy and 

 
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procedure is to timely and reasonably investigate all CRA consumer disputes,” timely respond 
to CRA consumer disputes, and “ensure accuracy of all credit reporting by updating or deleting 
reporting when warranted and appropriate.” ( Id. *SEALED* ¶ 33.) It requires that clients 
only send to collection debts that are accurate and owed, and that clients notify it immediately 
if they learn that a debt is inaccurate. (Id. *SEALED* ¶ 35.) Additionally, it requires its clients 
to notify it if a consumer has mad e a payment or if the client or property receives any 
information that affects whether the debt is accurate and owed. ( Id. *SEALED* ¶ 34.) I.Q. 
Data avers that it regularly and continuously trains its employees as to these policies. ( Id. 
*SEALED* ¶ 36.) 
Upon receiving th e dispute information Ms. Cooper had provided to the consumer 
reporting agencies , I.Q. Data investigated the debt. On April 2, 2024, it emailed Hudson 
Homes, stating that “[t]he consumer has provided information the account was closed in 
court, can you please confirm the balance is still due and provide any court documents 
pertaining to this account so we m ay validate the balance . . . .” (Id. *SEALED* ¶ 23; ECF 
No. 35 -6 Ex. E *SEALED* at 52.) Specifically, I.Q. Data stated in the email that it was 
missing court documents and a full ledger. (ECF No. 35 -6 Ex. E *SEALED* at 52.) The 
same day, an Assistant Portfolio Manager at Hudson Homes responded via email and stated: 
“The matter was not settled in court. The tenant was evicted because she did not pay and 
owes the amount stated.” ( Id. *SEALED* at 51.) Attached to this response was a resident 
ledger, but no court documents. See (ECF No. 35 -6 Ex. F *SEALED* ; ECF No. 35 -6 
*SEALED* ¶¶ 26–27). At some point, Hudson Homes sent I.Q. Data a Writ of Possession 

 
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Request, (ECF No. 35-6 Ex. G *SEALED* at 74), and a Notice of Eviction showing that the 
Sheriff was scheduled to evict Ms. Cooper on August 15, 2023 (id. *SEALED* at 66). 
Hudson Homes never informed I.Q. Data that the balance at issue “is not accurate for 
any reason whatsoever.” (ECF No. 35-6 *SEALED* ¶ 28.) I.Q. Data reviewed all documents 
and written communications from Ms. Cooper, all documentation from Hudson Homes, and 
its Work Card notes, which reflected all calls with Ms. Cooper and all activity on her account. 
(Id. *SEALED* ¶ 30.) Based on this review, it concluded that Ms. Cooper owed the balance 
because “she did not provide supporting documents to sufficiently demonstrate that the debt 
was not due at all, or that the amount reported was inaccurate, or that she had paid the alleged 
settlement amount, or that she had paid any amount, or that she was not liable for some other 
reason.” (Id. *SEALED* ¶ 31.) It concluded that it lacked sufficient information to change 
its determination that the balance was accurate, and it continued to report the debt as disputed. 
(Id. *SEALED* ¶ 32.) I.Q. Data avers that it did “not intentionally or knowingly report 
inaccurate information or intentionally or knowingly violate the law.” (Id. *SEALED* ¶ 37.) 
D. Ms. Cooper’s credit and emotional distress 
Ms. Cooper alleges that I.Q. Data’s credit reporting activity caused a “d eterioration in 
[her] credit standing and creditworthiness . . . .” (ECF No. 35 -2 at 23 , 20.) Ms. Cooper’s 
Experian credit report lists 66 accounts. (ECF No. 35-8 at 4 ¶ 12.) Her credit report reflects 
the balance reported by I.Q. Data, (id. at 10), $63,713 owed to the Department of Education, 
and $64,720 owed to Ally Financial, (id. at 7–8). At her deposition, Ms. Cooper stated that her 
credit score dropped by 50 or 60 points after the debt was reported, but she has not produced 
any documentation of such a decrease. (ECF No. 35-2 at 24.) 

 
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The debt at issue was reported to at least one potential creditor, Affirm , Inc. 
(“Affirm”),6 which declined to prequalify her for credit in May 2024 based on “the amount of 
[her] outstanding external debt.” (ECF No. 36 -11 at 2.) Ms. Cooper has applied for credit 
with Affirm more than ten times. (ECF No. 35-2 at 21.) Affirm declined to extend credit to 
her on June 19, 2022, and December 15, 2022 , (ECF No. 35-8 at 4 ¶ 10), but approved her 
for loans on December 26, 2023; February 1, 2024; October 3, 2024; December 5, 2024; and 
December 24, 2024, (id. at 4 ¶ 13). 
Ms. Cooper states that she has suffered “emotional distress . . . as a result of being 
pursued for this massive and false debt and from having this false information remain on [her] 
credit reports even after [she] provided Defendant with everything Defendant would need to 
know” to determine the reporting was inaccurate. (ECF No. 36-2 at 2 ¶ 9.) At her deposition, 
she explained that she is “definitely very anxious” and has “experienced a tremendous 
emotional distress” and “uncertainty . . . just about the day-to-day,” including living 
arrangements and worry as to a denial whenever she needs to use her credit. (ECF No. 35 -2 
at 29.) She has not seen a medical professional regarding her anxiety, and she is not taking 
any medication in relation to such anxiety. (Id.) 
III. Procedural History 
On July 23, 2024, Ms. Cooper initiated this action by filing in this Court a four -Count 
Complaint (ECF No. 1) against I.Q. Data. On October 2, 2024, she filed the operative 
Amended Complaint (ECF No. 6) alleging against I.Q. Data: (1) violation of the Maryland 
 
6 As Ms. Cooper explained in her deposition testimony, Affirm is “[s]imilar to a credit card.” (ECF No. 35-2 
at 21.) Applicants apply for credit in an amount of their choosing, Affirm performs a credit check, and it then 
approves or denies the requested loan accordingly. (Id.) 

 
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Consumer Debt Collection Act (“MCDCA”), MD. CODE ANN., COM. LAW § 14-201 et seq. 
(Count I); (2) violation of the Maryland Consumer Protection Act (“MCPA”), MD. CODE 
ANN., COM. LAW § 13-301 et seq. (Count II); (3) violation of the Fair Credit Reporting Act 
(“FCRA”), 15 U.S.C. § 1681s -2(a), (b) , based on failure to investigate (Count III); and 
(4) violation of the Fair Debt Collection Practices Act (“FDCPA”), 15 U.S.C. § 1692e(2)(A) 
(Count IV). At a hearing on June 2, 2026, this Court heard oral argument from both parties 
as to (1) Defendant’s Motion for Summary Judgment (ECF No. 35) (“Defendant’s Motion”) 
and (2) Plaintiff’s Cross -Motion for Summary Judgment as to Liability and Oppo sition to 
Defendant’s Motion (ECF No. 36) (“Plaintiff’s Cross-Motion”). 
STANDARD OF REVIEW 
Rule 56 of the Federal Rules of Civil Procedure provides that a court “shall grant 
summary judgment if the movant shows that there is no genuine dispute as to any material 
fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a). A 
material fact is one that “might affect the outcome of the suit under the governing law.” 
Libertarian Party of Va. v. Judd , 718 F.3d 308, 313 (4th Cir. 2013) (quoting Anderson v. Liberty 
Lobby, Inc. , 477 U.S. 242, 248 (1986)). A genuine issue over a material fact exists “if the 
evidence is such that a reasonable jury could return a verdict for the nonmoving party.” 
Anderson, 477 U.S. at 248. When considering a motion for summary judgment, a court’s 
function is limited to determining whether sufficient evidence exists on a claimed factual 
dispute to warrant submission of the matter for resolution at trial. Id. at 249. Trial courts in 
the Fourth Circuit have an “affirmative obligation . . . to prevent factually unsupported claims 
and defenses from proceeding to trial.” Bouchat v. Balt. Ravens Football Club, Inc., 346 F.3d 514, 

 
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526 (4th Cir. 2003) (quoting Drewitt v. Pratt, 999 F.2d 774, 778–79 (4th Cir. 1993)). 
In undertaking this inquiry, this Court must consider the facts and all reasonable 
inferences in the light most favorable to the nonmoving party. Judd, 718 F.3d at 312; see also 
Scott v. Harris , 550 U.S. 372, 3 80 (2007). This Court “must not weigh evidence or make 
credibility determinations.” Foster v. Univ . of Md.-E. Shore, 787 F.3d 243, 248 (4th Cir. 2015) 
(citing Mercantile Peninsula Bank v. French, 499 F.3d 345, 352 (4th Cir. 2007)); accord Jacobs v. N.C. 
Admin. Off. of the Cts ., 780 F.3d 562, 569 (4 th Cir. 2015). Indeed, it is the function of the 
factfinder to resolve factual disputes, including issues of witness credibility. See Tolan v. Cotton, 
572 U.S. 650, 656–57 (2014) (citing Anderson, 477 U.S. at 249). To survive summary judgment, 
the non-moving party must “do more than simply show that there is some metaphysical doubt 
as to the material facts.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp. , 475 U.S. 574, 586 
(1986). That is, the nonmoving party bears the burden to submit evidence that is “significantly 
probative” as to a genuine issue of material fact . Anderson, 477 U.S. at 249 –50. Where, as 
here, both parties file motions for summary judgment , this Court applies the same standard 
of review to both motions, considering “each motion separately on its own merits to determine 
whether either of the parties deserves judgment as a matter of law.” Defs. of Wildlife v. North 
Carolina Dep’t of Transp., 762 F.3d 374, 392 (4th Cir. 2014) (quoting Bacon v. City of Richmond, 
Va., 475 F.3d 633, 638 (4th Cir. 2007)). 
ANALYSIS 
As explained on the record and expounded below, Defendant’s Motion for Summary 
Judgment (ECF No. 35) is granted as to all counts such that Plaintiff’s Cross -Motion (ECF 
No. 36) must be denied. I.Q. Data argues that Plaintiff lacks Article III standing such that 

 
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this Court lacks subject matter jurisdiction over this matter . See (ECF No. 35 -1 at 12 –14). 
Alternatively, it contends that Ms. Cooper cannot establish the elements of her claims. 
I. Article III Standing 
“As the Supreme Court has consistently emphasized, Article III of the Constitution 
limits the jurisdiction of federal courts to Cases and Controversies.” Hutton v. Nat’l Bd. of 
Exam’rs in Optometry , Inc. , 892 F.3d 613, 619 n.5 (4th Cir. 2018) (internal quotation marks 
omitted) (quoting Lujan v. Defs. of Wildlife, 504 U.S. 555, 559 (1992)). “The requirement that a 
[p]laintiff possess ‘standing to sue ’ emanates from that constitutional provision.” Id. The 
burden to establish standing lies with the party invoking federal jurisdiction —here, Ms. 
Cooper. Lujan, 504 U.S. at 561. “[S]tanding is not dispensed in gross,” and “a plaintiff must 
demonstrate standing for each claim [she] seeks to press and for each form of relief that is 
sought.”7 Carolina Youth Action Proj. v. Wilson, 60 F.4th 770, 778 (4th Cir. 2023) (quoting Town 
of Chester v. Laroe Ests., 581 U.S. 433, 439 (2017)). 
“A plaintiff must demonstrate standing ‘with the manner and degree of evidence 
required at the successive stages of litigation.’” TransUnion LLC v. Ramirez, 594 U.S. 413, 431 
(2021) (quoting Lujan, 504 U.S. at 561). At the summary judgment stage, a plaintiff “can no 
longer rest on . . . ‘mere allegations,’ but must ‘set forth’ by affidavit or other evidence ‘specific 
facts, which for purposes of the summary judgment motion will be taken to be true.” Lujan, 
504 U.S. at 561 (internal citation omitted) (quo ting FED. R. CIV. P. 56(e)); see Fernandez v. 
RentGrow, Inc., 116 F.4th 288, 295 (4th Cir. 2024). That is, a plaintiff must set forth evidence 
 
7 Ms. Cooper’s state-law claims in this case incorporate her federal claim under the FDCPA such that, if she 
has standing under that claim, she also has standing for her state law claims. 

 
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that, taken as true, establishes that she has “(1) suffered an injury in fact, (2) that is fairly 
traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by 
a favorable judicial decision .” Dreher v. Experian Info. Sols., Inc. , 856 F.3d 337, 343 (4th Cir. 
2017) (quoting Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016)). Although Defendant challenges 
Ms. Cooper’s ability to establish a concrete injury traceable to its conduct, as explained on the 
record and below, Ms. Cooper has established standing at this summary judgment stage. 
“A plaintiff can show an ‘injury in fact’ when . . . she suffers ‘an invasion of a legally 
protected interest which is concrete and particularized, as well as actual or imminent.’” Piney 
Run Preservation Ass’n v. Cnty. Comm’rs of Carroll Cnty., 268 F.3d 255, 263 (4th Cir. 2001) (quoting 
Friends of the Earth, Inc. v. Gaston Copper Recycling Corp. , 204 F.3d 149, 154 (4th Cir. 2000)). 
“Crucially, concreteness and particularization are distinct requirements for injury -in-fact; the 
former is ‘quite different’ from the latter.” Baehr v. Creig Northrop Team, P.C. , 953 F.3d 244, 
252 (4th Cir. 2020) (quoting Spokeo, 578 U.S. at 340). An injury is concrete “if it ‘actually 
exist[s].’” Id. (quoting Spokeo, 578 U.S. at 340). Analysis of whether an injury is sufficiently 
concrete to confer Article III standing depends on whether the injury is tangible or intangible. 
TransUnion, 594 U.S. at 425. As to tangible injuries, the concreteness inquiry is straightforward: 
“If a defendant has caused physical or monetary injury to the plaintiff, the plaintiff has suffered 
a concrete injury in fact under Article III.” Id. Intangible injuries, however, involve a more 
protracted review of whether the harm has “a close relationship to harms traditionally 
recognized as providing a basis for lawsuits in American courts.” Id. (collecting cases). Thus, 
a statutory violation alone may not always form an injury-in-fact. Baehr, 953 F.3d at 252 (citing 
Spokeo, 578 U.S. at 341). 

 
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Once a plaintiff has shown a concrete injury, she must also establish that the claimed 
injury is “fairly traceable to” the defendant’s conduct. Lujan, 504 U.S. at 560–61. As the U.S. 
Supreme Court has explained, “the causation element of standing does not require the 
challenged action to be the sole or even immediate cause of the injury.” Sierra Club v. U.S. 
Dep’t of the Interior, 899 F.3d 260, 284 (4th Cir. 2018) (citing Bennett v. Spear, 520 U.S. 154, 168–
69 (1997)). Nor does traceability “mean that plaintiffs must show to a scientific certainty that 
defendant’s [conduct] caused the precise harm suffered by the plaintiffs.” Mayor & City Council 
of Balt. v. Wells Fargo Bank, N.A. , Civ. No. JFM-08-62, 2011 WL 1557759, at *2 (D. Md. Apr. 
22, 2011) (quoting Gaston Copper Recycling Corp. , 204 F.3d at 161). Nevertheless, where “‘the 
line of causation . . . is too attenuated’ or ‘highly indirect,’ the plaintiff’s injury is not ‘fairly 
traceable’ to the defendant and the plaintiff will not have standing.” Id. (quoting Allen v. Wright, 
486 U.S. 737, 757 (1984)); see also Bishop v. Bartlett, 575 F.3d 419, 425 (4th Cir. 2009) (explaining 
plaintiff lacks standing if an injury results from a non-party’s conduct). 
Although Ms. Cooper argues that emotional distress constitutes her “main damages in 
this case,” (ECF No. 36 -1 at 16), she also contends that she suffered a concrete injury when 
Affirm denied her credit after reviewing a consumer report containing the disputed debt. (Id. 
at 18–19.)8 Although I.Q. Data argues that Ms. Cooper has not established a concrete injury-
 
8 As explained at the hearing of June 2, 2026, because the Court concludes that the denial of credit is a concrete 
injury, it does not reach Ms. Cooper’s assert ed emotional distress. The Court notes, however, that i n a prior 
memorandum opinion in this case, it explained that the Fourth Circuit previously determined that allegations 
of emotional distress “as a consequence of [a defendant’s] alleged violations of the FDCPA’s proscribed 
practices” are sufficient to establish a concrete injury at the pleading stage. See (ECF No. 10 at 9 –10 (citing 
Moore v. Blibaum & Assocs., P.A., 693 F. App’x 205, 206 (4th Cir. 2017) (unpublished) and Ben-Davies v. Blibaum 
& Assocs., P.A., 695 F. App’x 674, 676–77 (4th Cir. 2017) (unpublished))). Approximately three months later, 
the Fourth Circuit issued Holmes v. Elephant Insurance Company, 156 F.4th 413 (4th Cir. 2025) , in which it held 
that emotional distress “do[es] not suffice for standing on [its] own” and may only furnish standing for damages 
“when incurred in response to a separate imminent harm.” Id. at 435. 

 
16 
in-fact traceable to its conduct, (ECF No. 35-1 at 13–14), it acknowledged on the record that 
denial of credit may be sufficient to confer Article III standing. Although the U.S. Court of 
Appeals for the Fourth Circuit does not yet appear to have addressed whether denial of credit 
constitutes a tangible harm for standing, most federal courts to have considered the issue have 
held that denial of credit is a tangible harm that confers standing for FDCPA and FCRA 
claims. See Pinson v. JPMorgan Chase Bank, Nat’l Ass’n, 942 F.3d 1200, 1206–07 (11th Cir. 2019); 
Rydholm v. Equifax Info. Servs., LLC , 44 F.4th 1105, 1108 (8th Cir. 2022); Simonson v. IQ Data 
Int’l, Inc., 698 F. Supp. 3d 1055, 1061 –62 (W.D. Wisc. 2023) ; Sipe v. Equifax Info. Servs., LLC , 
Civ. No. 3:16 -6103, 2017 WL 253157, at *6 (S.D.W.V. Jan. 20, 2017 ); cf. Alston v. Freedom 
Plus/Cross River , Civ. No. TDC -17-0033, 2018 WL 770384, at *6 (D. Md. Feb. 7, 2018) 
(explaining plaintiff lacked standing where she “allege[d] no facts to show that she was denied 
credit, lost access to credit, or suffered any other economic harm”). But see Freeman v. Ocwen 
Loan Servicing, LLC, 113 F.4th 701, 709–10 (7th Cir. 2024) (holding statement that fourth party 
denied loan did not show concrete injury at summary judgment). 
Consistent with her burden to provide evidence of harm, see Fernandez, 116 F.4th at 
295, Ms. Cooper has proffered a May 1, 2024, letter from Affirm in which it stated: 
Thank you for your interest in a loan through Affirm issued by Celtic Bank, 268 
South State Street, Suite 300 Salt Lake City, UT 84111 USA. Our partner bank 
can’t prequalify you because of the amount of your outstanding external debt[.] 
(ECF No. 36 -11 at 2.) She testified that she could not identify another instance of being 
denied credit based on I.Q. Data’s reporting, but the denial of the May 2024 loan was the first 

 
17 
time that Affirm stated the reason of “outstanding external debt.” 9 (ECF No. 35 -2 at 23.) 
Such testimony and evidence are sufficient to establish concrete harm based on denial of credit 
traceable to Defendant’s conduct in reporting the debt. See, e.g., Merchant v. Equifax Info. Servs., 
LLC, 616 F. Supp. 3d 146, 150 (D. Mass. 2022) (holding FCRA plaintiff established standing 
at summary judgment by producing broker’s affidavit “indicating that Plaintiff was unable to 
obtain refinancing for months due to the purported freeze on his Equifax account”). 10 
Although the Affirm letter does not overtly reference the disputed rent debt, Ms. Cooper has 
testified that “anything that was on [her] credit report before IQ Data reported this was on 
there at the time of the other times that [she] applied [for credit with Affirm], and it wasn’t a 
factor.” (ECF No. 35-2 at 23.) Construing all facts in Ms. Cooper’s favor, see Lujan, 504 U.S. 
at 561, the denial is traceable to I.Q. Data’s conduct in reporting the debt.11 As stated on the 
record, therefore, Ms. Cooper has established standing. 
 
9 She also testified in her deposition that she is “very fearful to apply for credit ,” (ECF No. 35-2 at 28), but 
such “deterrence from accessing the credit market” does not support standing. Evans v. Am. Collection Enter., 
624 F. Supp. 3d 593, 600 (D. Md. 2022). 
10 As discussed on the record, Ms. Cooper may also be able to establish a concrete injury in fact based on 
reputational harm from the inclusion of the debt on a consumer report disseminated to Affirm. See (ECF No. 
36-1 at 18–19.) The Supreme Court in TransUnion LLC v. Ramirez, 594 U.S. 413 (2021), held that dissemination 
of credit reports flagging named consumers as “potential matches” to individuals on a list of “specially 
designated nationals” who threaten terrorism constituted a concrete injury akin to the common law tort of 
defamation. Id. at 419, 432. The Fourth Circuit has held that where an injury is purely reputational, federal 
courts must evaluate the nature of the disclosure to determine whether it satisfies the traditional defamation 
requirement that the party to which the information was disclosed “understand[s] [the publication’s] defamatory 
significance.” Fernandez, 116 F.4th at 296. Regardless of reputational harm, however, denial of credit alone is 
sufficient to confer standing. 
11 Although I.Q. Data notes that Affirm subsequently approved Ms. Cooper for two loans in February 2024 
and October 2024, both periods in which the amount of outstanding external debt reflected the disputed rent 
debt at issue , consideration of such denials would involve drawing inferences against Ms. Cooper as to 
traceability, which is not permissible at summary judgment. 

 
18 
II. Legal issues as to rent debt 
Undergirding the parties’ arguments for summary judgment are threshold legal disputes 
as to whether an unlicensed landlord may use debt collection practices other than litigation to 
collect rent accrued while a property was unlicensed and the legal effect of the consent 
judgment issued in May 2023 . Before reaching the parties’ arguments as to the merits, 
therefore, this Court evaluates the legal inquir ies as to (1) the existence of the debt; (2) the 
accuracy of the amount of the debt; and (3) the collectability of the debt. 
A. Existence of rent debt 
As Maryland’s highest court recently confirmed in Assanah-Carroll v. Law Offices of 
Edward J. Maher, P.C. , 281 A.3d 72 (Md. 2022), 12 a landlord in Maryland may not initiate “a 
summary ejectment proceeding to collect unpaid rent where the landlord lacks a rental 
license.”13 Id. at 94. Accordingly, this Court and Maryland courts generally have held that a 
landlord cannot enforce a tenant’s obligation to pay rent accrued while a property was not 
licensed. See Aleti v. Metro. Balt., LLC, 279 A.3d 905, 931 (Md. 2022); Blizzard v. Hunter Warfield, 
Inc., Civ. No. ABA-23-3374, 2026 WL 274616, at *6 (D. Md. Feb. 3, 2026); Hall v. Heather Hill 
Property Co., LLC , Civ. No. ABA -25-0238, 2026 WL 279112, at *5 (D. Md. Feb. 3, 2026); 
Zambali v. Shulman Rogers, P.A., Civ. No. SAG-23-3194, 2024 WL 3161590, at *5 (D. Md. June 
25, 2024). As Judge Gallagher of this Court has explai ned, however, a tenant’s “debt d[oes] 
not disappear simply because his landlord did not have a license . . . The landlord simply could 
 
12 As noted on the record, the Assanah-Carroll case addressed two questions certified to the Supreme Court of 
Maryland by Judge Blake of this Court. 281 A.3d at 75–76. 
13 To the extent that Hudson Homes—the original creditor—did not have the right to collect rent for a period 
in which it was unlicensed, I.Q. Data also would not have a right to collect such debt. See, e.g., Chavis v. Blibaum 
& Assocs., P.A., 264 A.3d 1254, 1269 (Md. 2021) (explaining a plaintiff may have a claim under MDCA where 
debt collector claims amount that it knows it lacks the right to collect). 

 
19 
not collect the debt using the judicial process .” Zambali, 2024 WL 3161590, at *6. It is 
undisputed that Ms. Cooper has not paid the $47,575 in rent at issue. Thus, regardless of 
whether Hudson Homes was unlicensed and could not enforce her obligation to pay rent, she 
still owes rent. 
B. Accuracy of amount of rent debt 
As set forth on the record, the consent judgment issued by the District Court for 
Baltimore City, Maryland, on May 26, 2023, was a judgment for possession. In issuing that 
judgment, the district court stated on the record that it was “entering judgment in favor of the 
landlord for possession, for rent, due and unpaid in the amount of $8,22 1.93 by 
consent . . . Execution will be stayed until June 9th.” (ECF No. 35 -5 at 4–5.) This consent 
judgment is governed by § 8-401 of Maryland’s Real Property Article, which controls summary 
ejectment proceedings and allows a landlord to seek either or both of two distinct remedies: 
(1) a judgment for possession ; and (2) a money judgment for rent. To obtain a money 
judgment for rent, the landlord must request such “a judgment for the amount of rent due, 
costs, and any late fees . . .” in addition to requesting to repossess the premises. MD. CODE 
ANN., REAL PROP. § 8-401(b)(1)(iv); see Brown v. Housing Opportunities Com’n of Montgomery Cnty., 
714 A.2d 197, 200 & n.1 (Md. 1998) (explaining § 8 -401 “permits a landlord to recover 
possession of leased premises” and separately noting “court may also enter a money judgment 
for the rent due”). 
A judgment for possession authorizes a landlord to begin the process to evict the tenant 
and reclaim possession of the premises. MD. CODE ANN., REAL PROP. § 8-401(f)(1). The 
Supreme Court of Maryland very recently explained that, under § 8-401, the district court at a 

 
20 
summary ejectment proceeding for possession is required to determine the precise amount of 
unpaid rent due. Kapneck 14-16, LLC v. Bkeezy’s Speakeasy, LLC, -- A.3d --, 2026 WL 1158049, 
at *14 (Md. 2026). Generally, where the district court has issued a judgment of possession in 
favor of the landlord, the tenant has a “right to redemption of the leased premises” if she 
“tenders to the landlord the amount of the judgment, as well as any court -awarded costs and 
fees, before the execution of the judgment.” Pettiford v. Next Gen. Tr. Serv. , 226 A.3d 15, 33 
(Md. 2020) (quoting Cane v. EZ Rentals, 149 A.3d 649, 652 (Md. 2016) ). Thus, the statutory 
requirement that the court determine the amount of rent due and owing in part notifies the 
tenant of the amount of money she must pay to avoid eviction. As distinct from a judgment 
for possession, a monetary judgment for rent is an enforceable civil judgment. It authorizes 
“a judgment creditor to obtain possession of the assets of a judgment debtor in order to satisfy 
the debt or damages recovered by the judgment.” Rentals Unlimited, Inc. v. Adm’r, Motor Vehicle 
Admin., 405 A.2d 744, 751 (Md. 1979). 
The record in this case reflects that the consent judgment is a judgment for 
possession—but not a money judgment—in favor of Hudson Homes. See (ECF No. 35-4 at 
7 (consent judgment with checkbox marked that it is a “[j]udgment in favor of landlord for 
possession of the premises and costs” and checkbox for money judgment and associated 
amount left blank)) ; (ECF No. 35 -5 at 4 –5 (transcript of summary ejectment proceeding in 
which district court stated it was “entering judgment in favor of the landlord for pos session, 
for rent, due and unpaid in the amount of $8,221.93 by consent . . . ”)).14 Consistent with the 
 
14 The record further reflects that Hudson Homes requested a judgment for possession and not a money 
judgment because, as Plaintiff’s counsel noted on the record, it effectuated service only by affixing notice of 
intent to the door of the property, (ECF No. 35-4 at 6–7), but a money judgment requires personal service. 

 
21 
requirements of Maryland’s Real Property Article § 8-401, Kapneck 14-16, -- A.3d --, 2026 WL 
1158049, at *14, the district court determined that Ms. Cooper owed $8,221.93. As a judgment 
for possession only, however, the consent judgment is not conclusively determinative of the 
amount of rent owed. Ms. Cooper testified that the district court explained that Hudson 
Homes could not collect rent accrued while it was unlicensed, ( ECF No. 35 -2 at 17 –18). 
However, this determination appears neither in the transcript of the proceeding nor in the 
judgment. See (ECF No. 35-4 at 7; ECF No. 35-5 (making no mention as to Hudson Homes’ 
licensure)). Thus, neither the judgment for possession nor the asserted lack of licensure alter 
the un disputed fact that Ms. Cooper failed to pay rent in the total amount—including 
interest—of $47,575.00. That is, the debt at issue is accurate.15 
C. Enforceability of rent debt 
Although I.Q. Data reported an accurate amount of debt, the enforceability via collections 
proceedings of a rent debt accrued while a property is unlicensed presents a more nuanced 
question.16 In Assanah-Carroll, Maryland’s highest court determined that landlords cannot use 
summary ejectment proceedings to collect rent for a period in which they were unlicensed . 
281 A.3d at 100. It also appeared to hold that landlords cannot use lesser collection activities 
to collect such rent. 17 See id. at 100–101. As this Court has recognized, however, Assanah-
 
15 Although Plaintiff raises several arguments as to the preclusive effect of a consent judgment generally, see, 
e.g. (ECF No. 36-1 at 19–21), the critical issue in this case is not whether the judgment was a consent judgment 
but rather that it was a judgment for possession, as distinct from a money judgment for rent. As Plaintiff 
argues, a “consent judgment memorializes the agreement of the parties, pursuant to which they have 
relinquished the right to litigate the controversy in exchange for a certain outcome . . .,” Pettiford, 226 A.3d at 
26 (quoting Long v. Maryland , 807 A.2d 1, 7 (Md. 2002)) . A judgment for possession , however, does not 
determine all rent owed as would a money judgment for rent. 
16 As relevant to Ms. Cooper’s case, Article 13 § 5-4 of the Baltimore City Code requires landlords to be licensed 
to collect rental payments. As noted above, Defendant disputes whether Hudson Homes was unlicensed. 
17 In pertinent part, Maryland’s highest court held: 

 
22 
Carroll “did not expressly define what constitutes ‘unlawful collection activity’ in the context 
of” an unlicensed landlord. Hall, 2026 WL 279112, at *4. The parties have identified no cases 
in which a tenant alleges violation of the MCDCA and MCPA based on debt collection 
activities after a landlord received a judgment for possession. 
This Court has recently considered Assanah-Carroll in similar circumstances. In Zambali 
v. Shulman Rogers, P.A. , 2024 WL 3161590 (D. Md. June 25, 2024), Judge Gallagher of this 
Court determined that a tenant could not establish a cognizable injury where he admitted that 
he did not pay rent to an unlicensed landlord who then hired a firm to sue for the unpaid rent. 
This Court construed Maryland law to prohibit an unlicensed landlord from using “Maryland 
courts to collect [a rental debt]” but held that the tenant’s “rent could be charged” and his 
debt still existed. Id. at *6. Relatedly, in Blizzard v. Hunter Warfield, Inc., 2026 WL 274616 (D. 
Md. Feb. 3, 2026), Judge Ableson of this Court explained that “[a] landlord is prohibited from 
engaging in . . . lesser collection activities for periods where the property was unlicensed, but 
these activities do not give rise to a private right of action under the MCDCA or the MCPA.” 
Id. at *5; see also Hall, 2026 WL 279112, at *6 (dismissing in part MCDCA claim because rent 
payments were voluntary unless made under court order). These cases suggest that unlicensed 
 
Where a municipality or county enacts a rental license law, which conditions the performance 
of a residential lease upon the issuance of a rental license, and a landlord fails to possess a valid 
license for a period of a tenant’s occupancy, a landlord may not utilize the courts, whether through a 
common law breach of contract action, or a statutory action arising under Title 8 of the Real Property Article 
to recover unpaid rent that is attributable to the unlicensed period . . . . 
 
E. Given our holding that a landlord may not engage in debt collection activities or pursue claims against a 
tenant who has failed to pay rent attributable to a period during which the landlord was unlicensed, a tenant 
may have a right of action under the MCDCA and the MCPA where the landlord engages in 
such activity, and the tenant can establish that the unlawful conduct caused damages. 
Assanah-Carroll, 281 A.3d at 100–01 (emphasis added). 
 

 
23 
landlords cannot refer unpaid rent to collect ions, but payment of rent to an unlicensed 
landlord based on collection activities cannot establish damages under the MCDCA or MCPA. 
In this case, however, Ms. Cooper’s damages are not based on any payment of rent —it is 
undisputed that she has not paid the rent at issue—but upon Affirm’s denial of a loan in May 
2024 after I.Q. Data reported the debt. With this legal backdrop in mind, the Court addresses 
Ms. Cooper’s claims in turn, beginning with her federal claims. 
III. Count III: Violation of the federal Fair Credit Reporting Act, 15 U.S.C. 
§ 1681s-2(a), (b) 
In Count III, Ms. Cooper alleges that I.Q. Data violated the Fair Credit Reporting Act, 
15 U.S.C. § 1681s -2(a), (b), by willfully or negligently failing to conduct a reasonable 
investigation of her dispute and continuing to report an inaccurate rent delinq uency on her 
credit reports. Specifically, she alleges that I.Q. Data violated FCRA § 1681s-2(a), (b), by either 
willfully or negligently: (1) failing to conduct an investigation of the information that she 
disputed; (2) failing to report the results of t he investigation to the credit reporting agencies; 
(3) failing to report an accurate status of the inaccurate information to the credit reporting 
agencies; (4) failing to properly participate, investigate, and comply with the reinvestigations 
conducted by the consumer reporting agencies; (5) continuing to furnish and disseminate 
inaccurate and derogatory credit, account and other information to the credit reporting 
agencies; and (6) failing to comply with requirements imposed upon furnishers of information 
under the FCRA. See (ECF No. 6 ¶¶ 40–49). Even accepting, arguendo, Ms. Cooper’s assertion 
that Hudson Homes was not licensed until October 12, 2022, she cannot establish her FCRA 
claim. 

 
24 
Under the FCRA, furnishers of information to a consumer reporting agency have an 
obligation “to ensure that the information they provide . . . is accurate.” Roberts v. Carter-Young, 
Inc., 131 F.4th 241, 245 (4th Cir. 2025) (citing 15 U.S.C. § 1681s-2(a)). The Fourth Circuit has 
held that a successful FCRA claim requires a consumer to identify “facts that, if true, indicate 
an inaccuracy or incompleteness in their credit report that is objectively and readily verifiable.” 
Id. at 253. Whether information is “objectively and readily verifiable” depends on the facts of 
each case. Id. at 251. Furnishers “have neither the resources nor the expertise to conduct the 
level of investigation that takes place in judicial proceedings or to make the kinds of 
determinations about disputes that courts make.” Id. As a result, “a dispute that involves 
complex fact -gathering and in -depth legal analysis of the sort that courts would typically 
perform is not objectively and readily verifiable.” Id. 
In this case, as explained on the record, the parties’ dispute as to the collectability of 
the debt involves a complex legal inquiry —whether rent accrued while the property was 
unlicensed is collectible via debt collection —that is not readily verifiable. 18 As explained 
above, there exists some ambiguity in the Supreme Court of Maryland’s holding in Assanah-
Carroll. See, e.g. Hall, 2026 WL 279112, at *4. In cases addressing disputes as to rent payments 
to unlicensed landlords, this Court has held that the rent debt still accrues, see, e.g., Zambali, 
2024 WL 3161590, and an unlicensed landlords’ use of lesser debt collection activities is not 
always actionable, Blizzard, 2026 WL 274616, at *5. Thus, as explained on the record, the debt 
reported in this case was accurate. To the extent the debt was not fully enforceable, there exist 
 
18 I.Q. Data argues that Assanah-Carroll prohibited only use of the courts to collect rent accrued during a period 
in which a property was not licensed. See (ECF No. 35-1 at 15). Thus, it contends that an unlicensed landlord—
and, therefore, its debt collector—may use debt collection tactics to collect rent. 

 
25 
“unresolved legal disputes [that] ‘render [the] claim non-cognizable under the FCRA.’” Harvey 
v. USAA Fed. Savings Bank, No. 3:25cv155(RCY), 2026 WL 988508, at *6 (E.D. Va. Apr. 13, 
2026) (quoting Mader v. Experian Info. Sols., Inc., 56 F.4th 264, 270 (2d Cir. 2023)).19 
IV. Count IV: Violation of the federal Fair Debt Collection Practices Act, 
15 U.S.C. § 1692e(2)(A) 
For similar reasons, I.Q. Data is also entitled to summary judgment as to Ms. Cooper’s 
claim under the Fair Debt Collection Practices Act (“FDCPA”) in Count IV. Section 
1692e(2)(A) of the FDCPA prohibits a debt collector from “making false representations as 
to a debt’s character, amount, or legal status.” Webster v. ACB Receivables Mgmt., Inc. , 15 F. 
Supp. 3d 619, 625 (D. Md. 2014) (citing 15 U.S.C. § 1692e(2)(A)). “ To prevail in a private 
action, the plaintiff must prove that ‘[she] has been the object of collection activity arising 
from consumer debt, (2) the defendant is a debt [ ] collector as defined by the FDCPA, and 
(3) the defendant has engaged in an act or omission prohibited by the FDCPA.’” Id. (quoting 
Stewart v. Bierman, 859 F. Supp. 2d 754, 759–60 (D. Md. 2012)). The FDCPA does not consider 
the debt collector’s intent. See Yu v. Kevin B. Wilson L. Offs., 919 F. Supp. 2d 661, 664 (D. Md. 
2013). As acknowledged on the record, the parties dispute the third element of Ms. Cooper’s 
FDCPA claim: whether I.Q. Data has falsely represented the character, amount, or legal status 
of the debt in violation of § 1692e(2)(A). As to the character or amount of the debt, for the 
reasons set forth on the record and explained above, the debt reported was accurate. 
 
19 While this Court determined at the pleading stage that Ms. Cooper had sufficiently alleged readily verifiable 
information, at the summary judgment stage the record makes clear that the parties dispute the collectability of 
the debt, a legal inquiry of the sort courts—not furnishers—typically make. 

 
26 
Moreover, even assuming, arguendo, that the property was unlicensed for some portion 
of the relevant rental period, the statutory bona fide error defense shields I.Q. Data from 
liability. This defense protects debt collectors from liability under 15 U.S.C. § 1692e(2)(a) 
where they can establish by a preponderance of the evidence that “the violation was not 
intentional and resulted from a bona fide error notwithstanding the maintenance of 
procedures reasonably a dapted to avoid any such error.” 15 U.S.C. § 1692k(c); see Long v. 
McMullen, Drury & Pinder, P.A., Civ. No. RDB-10-2776, 2011 WL 4458849, at *5 (D. Md. Sep. 
23, 2011) (citing Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA , 559 U.S. 573, 589 
(2010)). In other words, the debt collection agency must “demonstrate that its violations were 
‘(1) unintentional, (2) [] bona fide error[s], and (3) made despite the maintenance of procedures 
reasonably adapted to avoid the error.’” Webster, 15 F. Supp. 3d at 626 (quoting Johnson v. 
Riddle, 443 F.3d 723 , 727–28 (10th Cir. 2006)). Notably, “[t]he FDCPA does not require a 
debt collector to engage in an independent investigation of the debt referred for collection.” 
Long, 2011 WL 4458849, at *5 (quoting Sayyed v. Wolpoff & Abramson, LLC , 733 F. Supp. 2d 
635, 646 (D. Md. 2010)). The defense protects debt collectors “provided there is a ‘colorable 
factual basis’ for a client’s claim.” Grant-Fletcher v. McMullen & Drury, P.A. , 964 F. Supp. 2d 
514, 528 (D. Md. 2013) (collecting cases). For this reason, the debt collector must prove “that 
it has pro cedures in place reasonably adapted to avoid the type of error that occurred.” 
Akalwadi v. Risk Mgmt. Alts., Inc., 336 F. Supp. 2d 492, 503–504 (D. Md. 2004); see Webster, 15 
F. Supp. 3d at 629 (requiring nexus between procedures and type of error). 
As the parties acknowledged on the record, there exist no genuine disputes of fact as 
to I.Q. Data’s investigation of the debt. Based on those undisputed facts, no reasonable jury 

 
27 
could determine that I.Q. Data lacked the appropriate procedures to avoid reporting a n 
uncollectible debt. I.Q. Data had no reason to question the validity of the debt that it initially 
reported to consumer reporting agencies: Ms. Cooper provided I.Q. Data no documentation 
regarding Hudson Homes’ licensure or the consent judgment, and I.Q. Data was not obligated 
to independently investigate the debt referred. Long, 2011 WL 4458849, at *5. Even after I.Q. 
Data received Ms. Cooper’s dispute materials from the consumer reporting agencies, it 
followed procedures designed to avoid collection of invalid debts. 
Specifically, it has identified procedures that “require[] its clients to notify [it] if a debt 
is not accurate, if there is a payment, or if the client or property receives any information that 
impacts whether the debt is accurate and owed ,” and to only send accurate and owed debts 
for collection. (ECF No. 35-6 *SEALED* at 5 ¶ ¶ 34, 35.) It had a contractual relationship 
with a third-party entity for quality control, including compliance and procedures such as: (1) 
referring dispute letters and associated information to the quality department; (2) review ing 
the dispute; and (3) requesting verification from the client as to relevant documents and the 
balance. (ECF No. 35 -7 at 10.) The deposition of the I.Q. Data consultant who contacted 
Hudson Homes about Plaintiff’s dispute reflects that she was trained with an overview of the 
American legal system. (ECF No. 36 -10 at 6 –7.) Although Plaintiff emphasizes that the 
deposition testimony of I.Q. Data’s corporate designee reflects that she did not know whether 
I.Q. Data had procedures to confirm a Maryland landlord’s licensure, (id. at 22), she defines 
the relevant procedures too narrowly. In this case, even assuming the truth of Ms. Cooper’s 
assertion that Hudson Homes was unlicensed such that some of the debt was not collectible, 
there is a clear nexus between I.Q. Data’s debt verification procedures and the error at issue—

 
28 
reporting a partially uncollectible debt. I.Q. Data appropriately relied on the documentation , 
including a full rent ledger and eviction notice , provided by its client. As set forth on the 
record, I.Q. Data is entitled to summary judgment as to Count IV. 
V. Counts I and II : Violation of Maryland Consumer Debt Collect ion 
Act, MD. CODE ANN., COM. LAW § 14-202(3), (8), (11) and Maryland 
Consumer Practices Act, MD. CODE ANN., COM. LAW §§ 13-303, 13-
301(14)(iii) 
In Count I, Ms. Cooper alleges that I.Q. Data violated three provisions of the Maryland 
Consumer Debt Collection Act (“MCDCA”): (1) Section 14-202(3), which provides that a 
debt collector “may not . . . [d]isclose or threaten to disclose information which affects the 
debtor’s reputation for credit worthiness with knowledge that the information is false; ” (2) 
Section 14 -202(8), which provides that a debt collector “may not . . . [c]laim attempt, or 
threaten to enforce a right with knowledge that the right do es not exist;” and, (3) Section 14-
202(11), which bars a debt collector from engaging “in any conduct that violates §§ 804 
through 812 of the [FDCPA].” Ms. Cooper’s claim under the Maryland Consumer Protection 
Act (“MCPA”) in Count II is derivative of her claim in Count I. 
As an initial matter, Plaintiff acknowledged on the record that her claim under MCDCA 
§ 14-202(11) is wholly dependent on her claim under the FDCPA in Count IV. As explained 
on the record and above, she cannot establish that I.Q. Data violated the FDCPA. Thus, 
Defendant is entitled to summary judgment as to the claim under MCDCA § 14 -202(11). 
Furthermore, as set forth on the record and expounded below, Ms. Cooper cannot establish 
knowledge as to her remaining MCDCA claims in Count I . Accordingly, I.Q. Data is also 
entitled to summary judgment as to Count I and Count II. 
A. Claim under MCDCA § 14-202(3) in Count I 

 
29 
First, as to MCDCA § 14-202(3), Ms. Cooper cannot establish that I.Q. Data 
“disclose[d] information which affects [her] reputation for credit worthiness with knowledge that 
the information is false .” MD. CODE ANN., COM. LAW § 14-202(3) (emphasis added). As this 
court has recognized, liability under this provision requires evidence that the defendant 
“disclosed information with actual knowledge or reckless disregard as to the falsity of the 
information . . . .” Akalwadi, 336 F. Supp. 2d at 511. For the reasons discussed above and 
on the record , the debt that I.Q. Data reported was accurate . See, e.g. , Zambali, 2024 WL 
3161590, at *6. Thus, Ms. Cooper cannot establish that I.Q. Data reported the debt with the 
knowledge that it was false. 
B. Claim under MCDCA § 14-202(8) in Count I 
MCDCA § 14-202(8) prohibits a debt collector from “[c]laim[ing], attempt[ing], or 
threaten[ing] to enforce a right with knowledge that the right does not exist.” As Maryland’s highest 
court has explained, “a plaintiff may invoke § 14-202(8) when the amount claimed by the debt 
collector includes sums that the debt collector, to its knowledge, does not have the right to 
collect.” Chavis v. Blibaum & Assocs., P.A., 264 A.3d 1254, 1269 (Md. 2021). Thus, “allegations 
that a creditor attempted to collect an exc essive amount of a charge it was otherwise entitled 
to collect” may raise a claim under § 14-202(8). Howes v. SN Servicing Corp., Civ. No. CCB-20-
670, 2022 WL 4554857, at *3 (D. Md. Sep. 29, 2022). 
To show that a defendant acted with “knowledge ” under MCDCA, a plaintiff must 
show the defendant knew it lacked the right to collect the debt or acted with reckless disregard 
as to the debt’s validity. Ramirez v. LVNV Funding, Civ. No. ABA-24-2335, 2025 WL 1665388, 
at *5 (D. Md. June 12, 2025) . The knowledge requirement does not necessarily immunize a 

 
30 
defendant for a mistake of law, and “one who deliberately goes perilously close to an area of 
proscribed conduct shall take the risk that he may cross the line.” Smith v. Olivieri & Assocs., 
LLC, Civ. No. GLR-20-2598, 2022 WL 596805, at *9 (D. Md. Feb. 28, 2022) (quoting Spencer 
v. Hendersen-Webb, Inc., 81 F. Supp. 2d 582, 595 (D. Md. 1999)). Even so, “where the law is 
unsettled at the time the collector claims a right . . . to withstand summary judgment and 
eventually prevail at trial, a plaintiff must produce facts from which the trier of fact reasonably 
may infer that the defendant acted recklessly in claiming the right.” Chavis, 264 A.3d at 1273. 
Under such circumstances, a defendant’s recklessness is a question of fact. Id. at 1274. 
In this case, Ms. Cooper has produced no “facts from which a trier of fact reasonably 
may infer” that I.Q. Data acted recklessly. Id. at 1273. As discussed above and on the record, 
it is not entirely clear when a debt collector’s efforts to enforce a rent debt accrued in part 
while a property is unlicensed creates a cognizable claim under the MCDCA. See, e.g., Assanah-
Carroll, 281 A.3d at 100 (suggesting a tenant may have an MCDCA claim against landlord who 
engaged in collection activities); Blizzard, 2026 WL 274616, at *5 (explaining a landlord cannot 
use lesser collection activities to collect rent accrued while a property was unlicensed, “but 
these activities do not give rise to a private right of action under the MCDCA or the MCPA”). 
In this case, even accepting Ms. Cooper’s assertion that Hudson Homes did not license the 
property at Eldone Road, I.Q. Data only received information regarding the licensure issue 
when it obtained Ms. Cooper’s dispute materials in March 2024. Those disputes for the first 
time provided copies of an unsigned Baltimore City Licensing Verification Request dated June 
17, 2022, that suggested the property was not licensed at that time. 

31 
Upon receipt of Ms. Cooper’s dispute materials—including her letter to the consumer 
reporting agencies, a copy of the consent judgment, a copy of the Licensing Verification 
Request dated June 17, 2022, and a copy of her rent assistance statement —it contact ed 
Hudson Homes to receive a full rent ledger that confirmed the amount of rent owed. See 
(ECF No. 35 -6 *SEALED* at 3 –4 ¶¶ 19 –30). Ms. Cooper has identified no “facts” from 
which a reasonable juror could conclude that I.Q. Data acted recklessly by accurately reporting 
the full amount of rent accrued. At most, Ms. Cooper’s dispute materials included her own 
interpretation of the Assanah-Carroll case and an assertion that Hudson Homes was not 
licensed. I.Q. Data investigated Ms. Cooper’s dispute fully and confirmed the rent owed with 
Hudson Homes before continuing to report the data. As explained on the record, I.Q. Data 
is not obligated to follow Ms. Cooper’s legal conclusions about a heavily disputed area of law. 
The facts show that I.Q. Data legitimately believed that it had the legal right to collect the rent 
accrued. Powell v. Palisades Acquisition XVI, LLC, 782 F.3d 119, 128 (4th Cir. 2014). 
CONCLUSION 
For the reasons set forth on the record at the hearing of June 2, 2026, and expounded 
above, Defendant’s Motion for Summary Judgment (ECF No. 35) is GRANTED as to all 
claims. Accordingly, Plaintiff’s Cross-Motion for Summary Judgment (ECF No. 36) must be 
DENIED. 
A separate Order follows. 
Date: June 4, 2026 
Richard D. Bennett 
United States Senior District Judge
/s/

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