On January 9, 2020, the United States Court of Appeals for the Eleventh Circuit issued its decision in Williams v. First Advantage Lns Screening Solutions, a mixed-file case watched closely by the background screening industry.  As noted by a Troutman Sanders blog, the Court affirmed a $250,000 compensatory damages award and reduced a $3.3 million punitive damages award to $1 million.  The blog observed that, “[t]he decision addressed a basic legal requirement in the background screening industry: connecting background information to common names. The matching procedures involved in Williams are similar to those recently scrutinized by the CFPB in another notable FCRA action that Troutman Sanders highlighted in the Southern District of New York (BCFP v. Sterling Infosystems). In that action, the CFPB also addressed procedures in attributing public records to persons with common names when other definitive unique identifiers, particularly a Social Security number, are absent, coming to similar conclusions as the Williams court.”