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Economic Loss Doctrine

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In Stasi v. Inmediata Health Grp. Corp., No. 19cv2353 JM (LL), 2020 U.S. Dist. LEXIS 217097 (S.D. Cal. Nov. 19, 2020), Judge Miller allowed a data security breach class action to proceed.  The basis of the class action was as follows: According to Plaintiffs' FAC,1 Inmediata provides billing and health record software and service solutions to healthcare providers. (FAC ¶¶… Read More

In In re Sonic Corp. Customer Data Sec. Breach Litig., No. 1:17-md-2807, 2020 U.S. Dist. LEXIS 114891 (N.D. Ohio July 1, 2020), Judge Gwin allowed a negligence claim to stand in a data breach case against Sonic.  The facts were as follows. Sonic restaurants are largely franchisee-owned. Sonic Defendants only directly own about 6% of Sonic restaurants. However, Sonic exerts… Read More

In In re Solara Med. Supplies, LLC Customer Data Sec. Breach Litig., No. 3:19-cv-2284-H-KSC, 2020 U.S. Dist. LEXIS 80736 (S.D. Cal. May 7, 2020), Judge Huff allowed a data breach claim to proceed. The facts were as follows: On November 13, 2019, Solara Medical Supplies, LLC ("Solara") notified its customers of a security incident that may have compromised the information… Read More