On January 13, 2021, the U.S. District Court for the District of Columbia denied a motion to compel arbitration filed by First Premier Corp. (“First Premier”) in a Fair Credit Reporting Act case, on the grounds that First Premier did not sufficiently establish that the card agreement containing the arbitration clause was mailed to the cardholder. Proctor v. First Premier Corp., 2021 U.S. Dist. LEXIS 6502 (D.D.C. Jan. 13, 2021).