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Remedies Keyed to Kovacic-Fleischer, 8th
Dun & Bradstreet, Inc. v. Greenmoss Builders, Inc.
Citation:
472 U.S. 749, 105 S. Ct. 2939, 86 L. Ed. 2d 593 (1985)Facts
Petitioner Dun & Bradstreet, a credit reporting agency, sent a confidential report to five paid subscribers falsely stating that respondent Greenmoss Builders had filed for voluntary bankruptcy. The error occurred when a seventeen-year-old employee reviewing bankruptcy pleadings inadvertently attributed a former employee’s bankruptcy petition to Greenmoss itself. Although Dun & Bradstreet’s standard practice was to verify such information with the businesses themselves, no verification was attempted before disseminating the report. After Greenmoss complained, Dun & Bradstreet issued a correction but refused to identify the recipients of the false report. The trial established the report was false and grossly misrepresented Greenmoss’s financial condition, causing injury to its business reputation.
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