4599 REVIEW DENIED In view of unrebutted testimony by landlord defendants that they would have denied plaintiffs’ rental applications on the ground that unlawful detainers had been filed against them regardless of the outcome of the proceedings, plaintiffs could not demonstrate they were damaged by credit reports that indicated unlawful detainers had been filed against them but omitted the favorable dispositions; plaintiffs therefore could not make out a case either under the Consumer Credit Reporting Agencies Act or the Unfair Competition Law; punitive damages cannot be awarded in the absence of actual damages.

TRUJILLO v FIRST AMERICAN REGISTRY (Credit Report) 157 CA4 628 [See: CivC 1785.1 etseq; 1786 etseq; Californians v Mervyn's 39 C4 223, P/AT 9/06; Ortiz v Lyon 157 CA4 604, T/AT 1/08]