In Grimes v. Rave Motion Pictures, a U.S. District Court in Alabama has held that the Fair Credit Reporting Act (FCRA) provision imposing strict liability for willful violations of credit card truncation requirements is unconstitutional. Under the Fair and Accurate Credit Transactions Act, which amended the FCRA, vendors are required to truncate credit card numbers and delete the card’s expiration date from receipts provided to customers to reduce identity theft. Section 1681n(a) of FCRA holds willful violators liable for actual damages or “damages of not less than $100 and not more than $1,000,” and “such punitive damages as the courts may allow.” The Grimes court found that the damages section as worded perfectly illustrated “void for vagueness,” noting that under the section’s language “the same customer could go to the same establishment many times in a single day to generate multiple non-complying receipts in order to assert multiple violations,” while having suffered no actual damages, creating a possibility for “misuse of the cards by customers of astronomical proportions more than the possibility of misuse of credit card information by thieves.” The court also found that the imposition of punitive damages on defendants where no actual harm was suffered would impose so severe a penalty in such disproportion to actual damages sustained as to deny due process of law.