The FCRA expressly exempts from preemption Massachusetts and California statutes on liability for information furnishers. Initially, courts held this exemption did not allow litigants a claim against information furnishers under California or Massachusetts law because the private right of action created by FCRA is not included in the exempted statutory provisions. As we previously reported, the winds shifted in California, where a California appellate court and the Ninth Circuit ruled otherwise. The winds also shifted in Boston, where a federal court recognized other courts had reached a different conclusion, but found a claim brought under the exempted Massachusetts provision was not preempted by FCRA. Catanzaro v. Experian Information Solutions, Inc., 09-105550, 2009 WL 4363207 (D. Mass. Dec. 1, 2009). The court did dismiss as preempted claims brought under other provisions in the same statute and the Massachusetts consumer protection statute.