Free Objections - District Court of Delaware - Delaware

Case 1:04-cv-01488-JJF Document 89-12 Filed 08/20/2007 Page1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
STEVEN G. MILLETT, MELODY J. )
MILLETT, On Behalf of )
Themselves and All Others )
Similarly Situated, )
)
Plaintiffs, )
)
vs. ) No. 05-599-SLR
>
TRUELINK, INC., a Trans Union )
Company, )
)
Defendant. )
VIDEOTAPED DEPOSITION OF LUCY DUNI
Taken on behalf of Plaintiff
March 28, 2007
Reported by Roselind C. Pisano, CSR
Illinois License No. 084-002031
POHLMAN REPORTING COMPANY (314) 421-0099
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Case 1:04-cv-01488-JJF Document 89-12 Filed 08/20/2007 Page 2 of 4
Page 108
1 knowing that, right now, your credit report is being
2 monitored for changes." And then, you know, it
3 details the changes.
4 So that's how it helps you to stay on top
6 of your credit, by informing you of critical
6 changes.
1 Q. If a consumer were not notified —— strike
9 that.
9 In what way does the Credit Monitoring
N service guard against identity theft?
11 A. It also details, you know, details it ——
U it's in the same way. It notifies you of critical
19 changes to your credit report.
M Q. What is a critical change?
N A. Some examples here are new inquiries,
16 address changes, new accounts opened in your name.
11 And then those are what we were talking about
N earlier, those critical changes.
19 Q. And why are those items selected as a
26 critical change?
21 A. Those are the —— we use a TransUnion watch
l 22 to —— and that's what it watches for. So that's how
29 they were selected.
N Q. Could you increase the number of items
26 which would be monitored for changes?
POHLMAN REPORTING COMPANY (3l4) 421-0099
a24ab50e-1c68-4d19-a681-48ccf371fch4

Case 1:04-cv-01488-JJF Document 89-12 Filed 08/20/2007 Page 3 of 4
Page 109
1 A. No.
2 Q. And why not?
3 A. Well because we're using that watch product
4 and those are the items that it watches for. We're
6 dependent on that product.
6 Q. There's a reference in the next paragraph
1 to Credit Specialists. Why are there —— why is the
9 word Credit Specialist capitalized?
9 A. As a title.
10 Q. And what is that intended to convey? Who
11 is a Credit Specialist?
12 A. Our —— we refer to our customer service
13 specialists as Credit Specialists because they've
M gone through certain training and they're trained to =
16 answer questions.
16 Q. Who provides that training?
11 A. I don't know the name of the certification
N off the top of my head.
19 Q. There is a certification process?
20 A. Uh—huh, yes. l
21 Q. I think you referred to this as a receipt,
22 did you not?
23 A. Yes.
24 Q. Does the appearance of a receipt change
23 over the course of time?
POHLMAN REPORTING COMPANY (314) 421-OO99
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Case 1:04-cv-01488-JJF Document 89-12 Filed 08/20/2007 Page 4 of 4
Page ll2
1 Q. Has the time period for providing the alert
2 always been 24 hours?
3 A. No.
4 Q. Is the time period for the 24 hour alert
8 the time period in existence today?
8 A. Yes.
7 Q. And what was the time period in 2005?
8 A. Well it was —— previously it was weekly,
8 but I don't remember when we changed from weekly to
18 daily.
11 Q. Has it ever been less frequently than
12 weekly?
13 A. No.
M Q. So even though a subscriber elected to
18 receive their all clear notifications on a monthly
18 basis, they would still be alerted within 24 hours
U of a key change?
18 A. Yes.
18 Q. And who determines whether or not a key
28 change has been made?
21 A. The credit bureaus report on the change to
22 us and then we pass that on to the customer.
23 Q. And you pass the alert on to a customer
24 through their e—mail?
28 A. Yes.
POHLMAN REPORTING COMPANY (3l4) 42l—OO99
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