I don't understand your question. For example, if I went to the office of a CRA and the receptionist, unprovoked, hit me over the head with a stapler, I wouldn't sue under provisions of the FCRA. I would sue for assault instead. I've read about Cliff Shepard; all of the cases described against creditors/CA's are FDCPA suits; the lone report of an FCRA suit was against the CRA. So far as I can tell, none of his suits have been FCRA suits against a creditor for reporting wrong information. I certainly agree that when dealing with an FCRA violation, it's much, much better to be going against the CRA.