UNITED STATES DISTRICT COURT
                     FOR THE NORTHERN DISTRICT OF TEXAS
                              DALLAS DIVISION

                    UNITED STATES OF AMERICA, Plaintiff,

                                     v.

              EXPERIAN INFORMATION SOLUTIONS, INC., Defendant.

                              CIVIL ACTION NO.

                               CONSENT DECREE

   WHEREAS: Plaintiff, the United States of America, has commenced this
   action by filing the Complaint herein; defendant has waived service of
   the Summons and Complaint; the parties have been represented by
   attorneys whose names appear hereafter; and the parties have agreed to
   settlement of this action upon the following terms and conditions,
   without adjudication of any issue of fact or law. This Consent Decree
   is for settlement purposes only and neither its execution by the
   parties nor its entry by the Court constitutes an admission by
   defendant that any law has been violated as alleged by the plaintiff,
   that there are valid grounds for the imposition of a civil penalty
   sought by the plaintiff, or that the facts alleged by the plaintiff,
   other than jurisdictional facts, are true. Defendant specifically
   denies the plaintiff's allegations and denies that it has violated any
   law as alleged by the plaintiff or otherwise.

   THEREFORE, on the joint motion of plaintiff and defendant, it is
   hereby ORDERED, ADJUDGED, AND DECREED as follows:

   1. This Court has jurisdiction of the subject matter and of the
   parties.

   2. The Complaint raises a legal dispute over which the Court has
   jurisdiction under Sections 5(a)(1), 9, 13(b) and 16(a) of the Federal
   Trade Commission Act, 15 U.S.C. §§ 45(a)(1), 49, 53(b) and 56(a), and
   under the Fair Credit Reporting Act, 15 U.S.C. §§ 1681-1681u.

                                DEFINITIONS

   As used in this Consent Decree:

   3. the Fair Credit Reporting Act, or FCRA, refers to 15 U.S.C.
   1681-1681u, as amended;

   4. the term "defendant" means Experian Information Solutions, Inc.,

                        UNITED STATES DISTRICT COURT
                     FOR THE NORTHERN DISTRICT OF TEXAS
                              DALLAS DIVISION

                    UNITED STATES OF AMERICA, Plaintiff,

                                     v.

              EXPERIAN INFORMATION SOLUTIONS, INC., Defendant.

                              Civil Action No.

                       COMPLAINT FOR CIVIL PENALTIES,
                        INJUNCTIVE, AND OTHER RELIEF

   Plaintiff, the United States of America, acting upon notification and
   authorization to the Attorney General by the Federal Trade Commission
   ("Commission"), for its complaint alleges as follows:

   1. Plaintiff brings this action under Sections 5(a)(1), 9, 13(b), and
   16(a) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C.
   §§ 45(a)(1), 49, 53(b), and 56(a), as amended, and under the Fair
   Credit Reporting Act ("FCRA"), 15 U.S.C. §§ 1681-1681u, as amended, to
   obtain monetary civil penalties and injunctive and other relief for
   defendant's violations of Section 609(c)(1)(B) of the Fair Credit
   Reporting Act, 15 U.S.C. § 1681g(c)(1)(B).

                           JURISDICTION AND VENUE

   2. This Court has jurisdiction over this matter under 28 U.S.C.
   §§ 1331, 1337(a), 1345, and 1355, and under 15 U.S.C. §§ 45(a)(1), 49,
   53(b), and 56(a). This action arises under 15 U.S.C. § 1681g(c)(1).

   3. Venue in the Northern District of Texas is proper under 15 U.S.C.
   § 53(b) and 28 U.S.C. §§ 1391(b-c) and 1395(a).

                                 DEFENDANT

   4. Defendant Experian Information Solutions, Inc. is an Ohio
   corporation with its office and principal place of business located at
   505 City Parkway West, Orange, California 92868. Experian's National
   Consumer Assistance Center is located in Allen, Texas. Experian is
   subject to prior orders of the Court in the Northern District of Texas
   related to the FCRA.

                       THE FAIR CREDIT REPORTING ACT

   5. The Fair Credit Reporting Act was enacted by Congress on October