Order on Plaintiff’s Motion for Default Judgment on Complaint to determine the dischargeability of credit card debt on grounds of false pretenses, false representations, or actual fraud under Section 523(a)(2)(A). The Court held that implied representations do not establish false pretenses or representations under 523(a)(2)(A). In considering the allegations of actual fraud, the Court considered the totality of the circumstances. Although Defendant more than doubled its balance by incurring 145 charges over a two and a half month period, such activity constituted a sudden change in Defendant’s spending habits, and some of the charges appeared questionable as necessities, Defendant had a six‐year history with American Express, the Court found no indication the card was used in anticipation of bankruptcy, and Defendant’s bankruptcy schedules contradicted Plaintiff’s assertions that Defendant was unemployed at the time the charges were incurred. In light of Plaintiff’s failure to establish by a preponderance of the evidence that Defendant possessed the subjective intent necessary to establish actual fraud under Section 523(a)(2)(A), and because entry of default judgment is discretionary, the Court denied Plaintiff’s Motion.