Curtis Collins disputed an Equable Ascent debt on his Experian credit file after defeating Equable’s collection lawsuit, but Experian relied on Equable’s response and left the debt reported. After the district court granted Experian summary judgment, Collins argued that Experian negligently and willfully violated the Fair Credit Reporting Act by failing to conduct a reasonable reinvestigation. The Eleventh Circuit held, as a matter of first impression, that a consumer seeking damages for a violation of FCRA § 1681i(a) need not show that the disputed information was published to a third party because that provision concerns information in the consumer’s file rather than a communicated consumer report. The court reversed that part of the judgment and remanded for the district court to decide whether Collins’s evidence of emotional distress created a jury question on actual damages. It affirmed summary judgment on the willfulness claim because Experian’s conduct could be negligent without meeting the higher standard of knowing or reckless disregard for the Act.