In Daubert v. NRA Group, LLC, 2016 WL 4245560, at *4 (M.D.Pa., 2016), Judge Caputo found that a Douglass-glassine window violation confers Article III standing under Spokeo.
Similarly, here, Plaintiff’s injury is also the unlawful disclosure of legally protected information. This injury is “clearly particularized,” as Plaintiff alleges that it was his personal identifying information that was disclosed. This injury is also concrete because as the Third Circuit explained in Nickelodeon, both history and the judgment of Congress demonstrate that the unlawful disclosure of legally protected information is a concrete harm that is sufficient to confer standing. Nickelodeon, 2016 WL 3513782, at *7; see also Google, 806 F.3d at 134 & n. 19 (citing Doe v. Chao, 540 U.S. 614, 641 (2004) (Ginsburg, J., dissenting) (explaining that standing was established based on allegations that a plaintiff’s Social Security number was disclosed)). This is consistent with the Supreme Court’s pronouncement in Spokeo that courts should look to both history and the judgment of Congress to determine whether an injury is sufficiently concrete. Spokeo, 136 S.Ct. at 1549. Therefore, based on the Supreme Court’s opinion in Spokeo and the Third Circuit’s opinion in Nickelodeon, I find that Plaintiff here has alleged a sufficiently concrete injury to confer standing.