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Data Breach Injury-in-Fact Corporate Counsel

WilmerHale

2024 Year in Review: Data Breach Litigation

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One of the main risks for a company in the event of a data breach is the threat of litigation. Data breach litigation continued to proliferate in 2024, as it has in prior years....more

Freiberger Haber LLP

Case of First Impression in the Appellate Division: Data Breach By Itself is Not An “Injury-in-Fact”

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The law can be funny. Not in a comedic way, but in a way that defies expectations about what is needed to bring a cause of action. Sometimes this is manifested in the quantum of evidence needed to bring an action and survive...more

Kilpatrick

Data breach class actions: SDNY finds standing based on sketchy injury-in-fact allegations

Kilpatrick on

Takeaway: Ever since the U.S. Supreme Court ruled in Clapper v. Amnesty Int’l USA, 568 U.S. 398, 416 (2013), that plaintiffs “cannot manufacture standing merely by inflicting harm on themselves based on . . . hypothetical...more

Ballard Spahr LLP

Third Circuit Becomes First Court of Appeals to Address Article III Standing in a Data Breach Case Post TransUnion

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The Third Circuit recently became the first federal appellate court to address the question of whether the victim of a data breach has Article III standing to bring a claim for damages based on the fear of identity theft...more

Genova Burns LLC

Potential Harm Enough For Class Action to Proceed in Data Breach Litigation

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The Third Circuit Court of Appeals has given new life to a putative class action suit led by a former employee of a company that suffered a ransomware attack, leading to her sensitive information being released onto the Dark...more

Kilpatrick

Data breach class actions: Southern District of New York dismisses action against health care providers for lack of standing

Kilpatrick on

Takeaway: In a prior article, we reported on the Second Circuit’s decision in McMorris v. Carlos Lopez & Associates, LLC, 995 F.3d 295 (2d Cir. 2021), in which the court, ruling on an issue of first impression, set out a...more

Saul Ewing LLP

After TransUnion, Lower Courts Grapple With Article III Standing in Data Breach Lawsuits

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In a data breach lawsuit, a plaintiff will sue a company that suffered a data breach in which the plaintiff’s personal information was stolen by cyberattackers. The plaintiff will claim that the breach has exposed the...more

Mintz - Privacy & Cybersecurity Viewpoints

The U.S. Supreme Court Raises the Bar on Standing in Privacy and Data Breach Class Actions

On Friday, a sharply divided U.S. Supreme Court issued a ruling, which significantly impacts the plaintiffs’ ability to pursue privacy and data breach class actions in federal courts. In TransUnion LLC v. Ramirez, Case No....more

Jackson Lewis P.C.

The Circuit Split Continues: 11th Circuit Weighs In On Standing In Data Breach Litigation

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The 11th Circuit recently weighed in on the hottest issue is data breach litigation, whether a demonstration of actual harm is required to have standing to sue. Joining several other circuit courts, the 11th Circuit in Tsao...more

Mintz - Privacy & Cybersecurity Viewpoints

The First Wave of CCPA Allegations Makes Its Way Into a New Data Breach Class Action Against Salesforce and Hanna Andersson

The companies Salesforce.com, Inc. and Hanna Andersson, LLC are on the receiving end of a novel lawsuit, which appears to be the very first data breach class action ever filed with alleged violations of the California...more

Jackson Lewis P.C.

Georgia Supreme Court May Weigh In On Standing In Data Breach Litigation

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The Georgia Supreme Court may weigh in on the hot issue plaguing data breach class action litigation across the nation, must a data breach victim suffer actual financial loss to recover damages, or is the threat of future...more

King & Spalding

D.C. Circuit Splits with Other Circuits by Holding that Risk of Identity Theft Following Data Breach Satisfies Pleadings-Stage...

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On June 21, 2019, the D.C. Circuit split with several other circuits in holding that alleging a heightened risk of identity theft following a data breach is enough to establish standing at the pleadings stage....more

Ballard Spahr LLP

8th Circuit Decision in SuperValu Class Action is a Reminder that Injury and Damages Aren’t the Same Thing.

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Last Friday we blogged on the Saks data breach class action, and in the process mentioned a trend among federal courts to reject fear of future identity theft claims in retail breach cases.  ...more

Ballard Spahr LLP

Court Ruling in Saks Data Breach Case Illustrates That Threshold for Article III Standing Is Low

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For years, plaintiffs in data breach class actions have argued that the threshold for Article III standing is low – and increasingly courts are accepting that argument....more

Bradley Arant Boult Cummings LLP

Injury-in-Fact vs. Actual Damages — Avoiding a Jurisdictional Sideshow in Data Breach Class Actions by Challenging Damages, Not...

Following the Supreme Court’s ruling in Spokeo v. Robins, which held that federal plaintiffs alleging a statutory violation must have suffered a real, concrete injury in order to have Article III standing, many defendants...more

Kilpatrick

Is standing overrated? Data breach defendants who lose standing battles end up winning dismissal

Kilpatrick on

Takeaway: In the wake of Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016), defendants in data breach class actions regularly move to dismiss on standing grounds, arguing the complaint’s allegations do not plausibly allege an...more

Jackson Lewis P.C.

Standing In Data Breach Litigation: Will The U.S. Supreme Court Weigh In?

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The U.S. Supreme Court may finally weigh in on the hottest issue in data breach litigation, whether a demonstration of actual harm is required to have standing to sue. Standing to sue in a data breach class action suit,...more

Mintz - Privacy & Cybersecurity Viewpoints

Court Rejects Neiman Marcus Data Breach Settlement Due To Injury-Based Class Conflicts

As previously noted in this blog, the Neiman Marcus payment card data theft class action reflects a lenient approach to the issue of standing in data breach cases. In that case, the Seventh Circuit rejected arguments that...more

Hogan Lovells

Data class actions in the US

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Over the past few years, there has been a surge in class actions challenging companies’ privacy and data security practices. But, while the number of class actions continues to grow, the suits face several significant...more

Carlton Fields

Fourth Circuit Holds Plaintiffs Who Allege Identity Theft Have Standing To Sue Post-Data Breach, But What Does It Mean For...

Carlton Fields on

The Fourth Circuit’s 2017 decision in Beck v. McDonald held that the mere fear of identity theft in the wake of a data breach was insufficient to confer Article III standing. ...more

Harris Beach Murtha PLLC

Uber Catches Break in Data Breach Class Action

Uber suffered a data breach in 2014 resulting in the compromise of more than 50,000 drivers’ personal information, including back account and social security numbers. Drivers brought a class action suit in federal court in...more

Ballard Spahr LLP

Seventh Circuit Reinstates Barnes & Noble Data Breach Class Action

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The U.S. Court of Appeals for the Seventh Circuit has reinstated a data breach class action filed against Barnes & Noble (B&N).  The litigation, styled as Dieffenbach v. Barnes & Noble, Inc., now heads back to the U.S....more

Fenwick & West LLP

Appellate Court Finds Risk of Identity Theft Sufficient to Establish Standing, Circuit Split Worsens

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The U.S. Court of Appeals for the Ninth Circuit has found that allegations of a future risk of identity theft resulting from a data breach are sufficient to establish standing....more

Fisher Phillips

Spokeo Speedwagon: Employers Forced To Take Privacy Breach Cases On The Run

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By now, most everyone has heard it from a friend who, heard it from a friend who, heard it from another about the U.S. Supreme Court’s 2016 decision in Spokeo, Inc. v. Robins. It is the case being cited across the country in...more

Carlton Fields

The Continuing Saga Of Standing In Data Breach Class Actions: The 8th Circuit Weighs In

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We previously reported on the developing circuit split over Article III standing in data breach class action cases. In August, the D.C. Circuit Court joined the Sixth, Seventh, and Ninth Circuits in finding that the...more

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