Van Straaten v. Shell Oil Products Co., LLC

Dist. Ct. erred in finding that defendant violated provisions of Fair and Accurate Credit Transactions Act (Act) when it printed on receipts at its gas pumps last four digits of what defendant called customer's account number as opposed to last four digits of primary account number contained on magnetic strip of credit card. While Act mandates that defendant not display more than last 5 digits of "card number" when printing receipts, Act does not define "card number," and plaintiffs conceded that digits defendant chose to print did not leave them at risk for identity theft. Moreover, plaintiff did not establish that defendant's practice of printing last four digits of account number constituted willful violation of Act where it was unclear that customer account number was not relevant number for purpose of enforcement of Act.