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Article III Data Breach Future Harm

WilmerHale

Year in Review: Top 2023 Data Breach Litigation Trends

WilmerHale on

One of the main risks that a company faces after a data breach is a potential lawsuit. Plaintiffs often will allege creative statutory and common law theories of harm after they learn that their personal information has been...more

Benesch

First Circuit Dives Into Standards for Concrete Harm in Data Breach Litigation

Benesch on

In the complex and rapidly evolving landscape of data breach litigation, the First Circuit’s recent case of Webb v. Injured Workers Pharmacy, LLC stands as a significant milestone, and it offers a wealth of insights for...more

Vinson & Elkins LLP

No (Actual) Injury, No Problem: Second Circuit Recognizes An “Increased-Risk” Theory Of Standing For Plaintiffs In Data Breach...

Vinson & Elkins LLP on

In McMorris v. Carlos Lopez & Associates, LLC, a data breach case, the Second Circuit held that plaintiffs may demonstrate standing based on a theory of “increased risk” of future identity theft or fraud following an...more

King & Spalding

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

King & Spalding on

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

K&L Gates LLP

Deepening the Divide: D.C. Circuit Continues Circuit Split Regarding Standing in Data Breach Class Action Based on Risk of Future...

K&L Gates LLP on

The D.C. Circuit Court of Appeals recently reaffirmed its position that a plaintiff can establish Article III standing (federal court subject matter jurisdiction) based solely on the risk of potential future harm following a...more

Fenwick & West LLP

Eighth Circuit Finds No Duty for Retailers to Safeguard Personal Data of Customers - Consumer Protection Violation Requires Actual...

Fenwick & West LLP on

Pursuing negligence claims in the Eighth Circuit following a data breach just got harder. On May 31, 2019, the U.S. Court of Appeals for the Eighth Circuit again dismissed the data breach claims in In re SuperValu, Inc....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

Carlton Fields

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

Carlton Fields on

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

Fenwick & West LLP

Litigation Alert: The Fourth Circuit Limits Standing to Bring Data Breach Cases

Fenwick & West LLP on

The U.S. Court of Appeals for the Fourth Circuit has made it more difficult to establish Article III standing in data breach cases both at the pleading stage and at summary judgment by requiring plaintiffs to allege and show...more

Butler Snow LLP

Data Breach Class Action Against Michael Stores Doesn’t Stick

Butler Snow LLP on

The arts and crafts retail chain Michael Stores Inc. (“Michaels”) received a late holiday gift in the form of a dismissal of a data breach class action lawsuit. On December 28, 2015, the U.S. District Court for the Eastern...more

Pillsbury Winthrop Shaw Pittman LLP

Seventh Circuit Finds Article III Standing for Data Breach Class Action Based on Allegations of Future Harm

In the wake of numerous data breach cases dismissed for lack of Article III standing based on the Supreme Court’s decision in Clapper v. Amnesty Int’l USA, 133 S. Ct. 1138, 1147 (2013), the Seventh Circuit Court of Appeals...more

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