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Data Security Standing

BakerHostetler

Courts Are Still Willing To Dismiss Data Breach Lawsuits for Lack of Standing

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In data breach litigation, courts generally find plaintiffs have standing such that their complaints may proceed past the pleading stage when it is alleged that sensitive information was impacted and there is an allegation of...more

Hinshaw & Culbertson - Consumer Crossroads

Navigating Standing Considerations in Data Breach Class Actions

The growing prevalence of data breaches has led to an uptick in class action litigation based on consumers' personal information allegedly being accessed. A common theme emerging in these lawsuits is plaintiffs claiming that...more

Clark Hill PLC

Illinois Supreme Court Affirms Dismissal of Data Breach Class Action for Lack of Standing

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On Jan. 24, the Illinois Supreme Court, in Petta v. Christie Business Holdings Company, PC, affirmed the dismissal of a putative class action following an alleged data breach because the named plaintiff failed to allege any...more

Vedder Price

Illinois Supreme Court: Increased Risk of Harm Arising from a Data Breach Is Insufficient to Confer Standing

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On January 24, 2025, the Illinois Supreme Court ruled in Petta v. Christie Business Holding Co., P.C., 2025 IL 130337, that a patient who alleged an increased risk of harm arising from a data breach at a medical clinic did...more

Ropes & Gray LLP

Unwrapping 2024’s Key Trends in Data Privacy Litigation

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Data breaches made headlines throughout 2024, affecting governments, health care groups, and telecoms. Follow-on litigation has kept pace. Nearly 4,000 class actions involving data privacy issues are estimated to be filed in...more

Pierce Atwood LLP

First Circuit Revives Data Breach Class Action Claims in Webb v. Injured Workers Pharmacy, LLC

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Courts and class action counsel have been considering what kinds of injuries can confer standing to pursue federal claims following the Supreme Court’s 2021 decision in TransUnion LLC v. Ramirez, which held that the...more

Orrick, Herrington & Sutcliffe LLP

11th Circuit orders reexamination of breach class boundaries

On July 11, a split U.S. Court of Appeals for the Eleventh Circuit partially vacated the greenlighting of two data breach class actions, holding that a district court must re-analyze the boundaries of the classes. Both the...more

Polsinelli

Current Turmoil and Future Risks in Resolving Data Breach Class Actions

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Data incident lawsuits, especially class actions, have the potential to create significant business disruption, loss of marketplace credibility, civil liability or regulatory exposure. Consequently, companies that experience...more

Kilpatrick

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

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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

McNees Wallace & Nurick LLC

Imminent and Substantial: The Third Circuit Holds That the Leak of Personal Information onto the Dark Web is Sufficient to...

A recent decision from the Third Circuit suggests that the leak of information onto the Dark Web provides standing to class action plaintiffs in data breach litigation. In Clemens v. ExecuPharm, Inc., 48 F.4th 146 (3d Cir....more

Pierce Atwood LLP

District of Massachusetts Dismisses Data Breach Class Action for Lack of Injury

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On October 18, 2022, in Webb v. Injured Workers Pharmacy, LLC, the District of Massachusetts dismissed a class action complaint brought by former pharmacy patients alleging that their sensitive personal information had been...more

Seyfarth Shaw LLP

First There Was Litigation; And Then There Was Standing

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Now more than ever, it is important for organizations to review and update their basic information security protocols (their incident response, business continuity and crisis communications plans), and to ensure they’re...more

Troutman Pepper Locke

Firmer Footing for Data Breach Standing, Thanks to the Second Circuit

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Instead of identifying traditionally “tangible” injuries, data breach plaintiffs typically point to the fact that they may be the victim of identity theft at some point in the future. Prior to late April 2021, the federal...more

King & Spalding

Second Circuit Finds Risk of Future Identity Theft Insufficient to Confer Article III Standing in a Data Security Class Action

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On April 26, 2021, the Second Circuit considered—for the first time in a published decision—the question of Article III standing in the context of a data security case. In McMorris v. Carlos Lopez & Associates LLC, the court...more

ArentFox Schiff

Privacy Update: Corporate Boards - Don’t Underestimate Your Role in Data Security Oversight

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The Federal Trade Commission (FTC) continues to put emphasis on the importance of corporate board involvement in privacy and data security. Corporate Boards: Don’t Underestimate Your Role in Data Security Oversight - The...more

Blank Rome LLP

Lessons Learned From Eleventh Circuit’s Dismissal of Data Breach Suit Alleging Only Increased Risk of Future Harm for Lack of...

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In the context of data breach class action litigation, the question of whether Article III standing can be satisfied is often dispositive of the outcome of an action. However, a deep circuit split currently exists between the...more

Kilpatrick

Data Breach Class Actions – Eleventh Circuit Finds Allegations of “Increased Risk” of Harm Insufficient to Confer Standing

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Takeaway: In Tsao v. Captiva MVP Restaurant Partners, LLC, 986 F.3d 1332, 1339 (11th Cir. 2021), the Eleventh Circuit held that evidence of a “mere data breach” is not sufficient to establish standing where the hackers...more

Shook, Hardy & Bacon L.L.P.

The Eleventh U.S. Circuit Wades into the Data-Breach-Standing Debate

Last week, in a 26-page opinion, the 11th U.S. Circuit Court of Appeals weighed in on two questions crucial to the viability of privacy and data breach litigation in federal court—and perhaps even in general. First, does a...more

Blank Rome LLP

Data Breach Defense

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Today, data breaches continue to proliferate at a rapid pace, often spurring consumer class action litigation in their wake. Oftentimes, a successful data breach suit can empty a corporate defendant’s coffers. For example,...more

Troutman Pepper Locke

No Federal Court Standing for Data Breach Claims Alleging Theft of Non-Sensitive Personal Information

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A federal court in California has ruled that the plaintiff in a putative class action alleging theft of non-sensitive personal information arising from a cybersecurity data breach lacks Article III standing to maintain his...more

Shook, Hardy & Bacon L.L.P.

Privacy and Data Security Alert | December 2019

SDNY Rejects Standing under “Increased Risk” Theory Where Data Not Targeted or Stolen - The Southern District of New York rejected a settlement that would have resolved a class action based on the unauthorized (and...more

Eversheds Sutherland (US) LLP

Passing the eye test - Defense strategies and the Biometric Information Privacy Act

As the use of biometric data continues to grow and become more prevalent across industries of all types and sizes, complying with data security and privacy laws has never been more critical or challenging. This is...more

Shook, Hardy & Bacon L.L.P.

Privacy and Data Security Alert | June 2019 #2

Maine Bill Requires ISPs to Obtain Opt-In Consent from Customers - The Maine legislature has passed a bill that requires internet service providers (ISPs) operating in Maine to obtain express, affirmative consent from...more

Proskauer - Law and the Workplace

Ill. Supreme Court: BIPA Plaintiffs Are Not Required to Show Actual Harm To Have Standing

On January 25, 2019, in a closely watched case, the Illinois Supreme Court ruled that a plaintiff need not allege or demonstrate actual harm to have standing to pursue a claim under the Illinois Biometric Information Privacy...more

Sheppard Mullin Richter & Hampton LLP

The Fight Over Standing Under the Biometric Information Privacy Act Continues in Illinois High Court

On November 20, 2018, the Illinois Supreme Court heard oral arguments in Rosenbach v. Six Flags Entertainment Corp. and Great America LLC to decide whether a technical violation of Illinois’ Biometric Information Privacy Act...more

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