In Carvalho v. Equifax Information Services, No. 09-15030 (9th Cir. Aug 18, 2010), plaintiff alleged that a furnisher of information to the credit reporting agencies violated section 1785.25(f) of the California Consumer Credit Reporting Agencies Act (CCCRA) by failing to conduct an adequate investigation after she notified the furnisher that she disputed a debt reported to the agencies. The Ninth Circuit held her claim was preempted by FCRA. The court concluded FCRA’s exemption of CCCRA section 1785.25(a) from preemption applied only to that section and not to any other sections of the statute.