In Piccini v. Wells Fargo Auto Finance, Inc. 2009 WL 307276 (D.Ariz. 2009), Judge Campbell of the District Court of Arizona enforced Wells Fargo’s arbitration clause to cover credit reporting claims under FCRA.  Judge Campbell explained


Plaintiff does not dispute the validity of his agreement with Wells Fargo, nor does he contend that the arbitration clause is unenforceable. Dkt. # 22 at 3. Instead, relying on Hyde v. RDA, Inc., 389 F.Supp.2d 658, 664 (D.Md.2005), Plaintiff argues that his claims are not significantly related to the lease agreement to fall within the arbitration provi-sion. Dkt. # 22 at 4. ¶ Plaintiff’s reliance on Hyde is mistaken. In that case, a car dealer obtained an unauthorized consumer credit report in order to furnish a “pre-qualifying” credit offer to a prospective purchaser. Hyde, 389 F. Supp 2d at 661. The purchaser subsequently accepted the dealer’s offer by signing an order form with an arbitration clause encompassing “all disputes, claims, or controversies arising from or relating to the Purchaser’s purchase of the Vehicle.” Id. (emphasis in original). The district court determined that no sig-nificant relationship existed between the arbitration clause and the purchaser’s FCRA claim because the dealer’s unauthorized credit inquiry pre-existed the order form; the dealer’s violation of FCRA was a separate transaction antedating the parties’ contractual relationship. Id. at 664.  ¶  Here, unlike Hyde, Plaintiff seeks recovery for credit reports published after he entered his agreement with Wells Fargo. Further, the arbitration clause is broader than in Hyde because it includes “[a]ny controversy or claim …including, but not limited to, those arising out of or relating to” the truck lease. Dkt. # 21-2 at 3 (emphasis added).  ¶  Plaintiff also argues that the arbitration clause is in-applicable to at least some credit reports following the lease agreement because his contractual privity with Wells Fargo ended when he paid off the lease in June, 2008, and erroneous reports may have occurred after that time. Dkt. # 22 at 5. Parties may, however, draft an arbitration clause broadly to reach “every dispute … having a significant relationship to the con-tract and all disputes having their origin or genesis in the contract.” See  Simula, 175 F.3d at 720-21 (giving expansive interpretation to an arbitration clause for claims “arising in connection with” a supplier’s con-tract); see also AT &  T Techs., Inc. v. Commc’ns Workers, 475 U.S. 643, 650, 106 S.Ct. 1415, 89 L.Ed.2d 648 (1986) ( “[A]n order to arbitrate the particular grievance should not be denied unless it may be said with positive assurance that the arbitration clause is not susceptible of an interpretation that covers the asserted dispute.”) (quoting United Steelworkers, 363 U.S. at 582-83). In fact, parties may agree to arbitrate disputes with only tenuous connections to their actual performance. See, e.g.,  Kiefer Specialty Flooring, Inc. v. Tarkett, Inc., 174 F.3d 907, 909 (7th Cir.1999) (noting that arbitration clauses for disputes “arising out of or relating to” an agreement are “extremely broad and capable of an extensive reach”). Even if Wells Fargo made some reports after the lease had been paid in full, those reports related to and had their origin in the parties’ contractual relationship.