Free Objections - District Court of Delaware - Delaware

Case 1:04-cv-01488-JJF Document 89-3 Filed 08/20/2007 Page1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
STEVEN G. MILLETT, MELODY J. )
MILLETT, On Behalf of ) _
Themselves and All Others ) Q
Similarly Situated, ) -
) I
Plaintiffs, ) 05-559-SLR
)
vs. )
)
TRUELINK, INC., A Trans Union )
Company, )
)
Defendant. ) ”
THE VIDEOTAPED DEPOSITION OF
JOHN DANAHER
Taken on behalf of the Plaintiff
March 27, 2007
Reported by Cheryl L. Sandecki, CSR, RPR g
Illinois License No. 084-03710 L
POHLMAN REPORTING COMPANY (3l4) 421-0099
ac243ba2-50d3-4721-8123-bd6eb01ca5c1

Case1:04—cv-01488-JJF Document 89-3 Filed 08/20/2007 Page2of3
Page 26 _
1 which one —— let me begin again, please. _
2 Can you generally describe the manner in l
3 which the credit monitoring product alerts a -
4 consumer to the key changes? Q
3 A. Do you mean to describe the process? -
3 Q. Please.
1 MR. O'NEIL: The process for alerting the
3 consumer of the key change?
9 MS. YEAGER: Correct. Q
N THE WITNESS: We are notified from one of ,
11 the credit bureaus that a change has taken
12 place, and we send the customer an E—mail
13 advising them that there has been a change and
M to come back onto our website to get the
13 details.
16 BY Ms. YEAGER; I
U Q. The customer who comes to the website to 1
N review the details, could you generally describe
19 what information they might see once they take that
29 step to come onto the website to review the changes
21 or the details that you were describing?
22 A. So, for example, if we send —— if there
23 has been a new inquiry, if you log onto the site,
M you will see generally the date of the inquiry and
23 who made the inquiry. You might get the location. Q
POHLMAN REPORTING COMPANY (3l4) 42l—OO99
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Case 1:04-cv-01488-JJF Document 89-3 Filed 08/20/2007 Page 3 of 3
Page 118
1 which of these would trigger an alert to one of
2 your customers?
5 A. Just the one that I defined where somebody
1 is using your personal information to attempt to
5 get credit in your name.
5 Q. If an individual were using your
1 Social Security number and that was the only piece
8 of personal identification that was being reported
2 fraudulently, would the original holder of the
N Social Security number be notified?
11 A. No.
12 Q. Why not?
B A. Because there is no way to verify who is
M the legitimate holder of that Social Security
15 number.
16 Q. lf you had two —— do you need to take a
11 break?
18 A. No.
N Q. If you had two customers who wanted to
20 subscribe to Credit Monitoring in 2003 and both of
21 those customers tried to sign up for Credit
N Monitoring with your company in 2003 using the same
25 Social Security number, could they both do so?
M A. Our system only allows for one account, a
25 unique Social Security number. So on our system,
POHLMAN REPORTING COMPANY (314) 421-0099
ac243ba2-50d3-4721-8123-bd6eb01ca5c1