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I was doing a research project on data breaches and Art III standing for a while but I sort of ramped down the intensity in May, and wanted to catch up a bit. Does anyone know if the theory of recovery in Claridge v. RockYou, Inc., 785 F. Supp. 2d 855 stating that

 "defendant's customers, including plaintiff, "pay" for the products and     
services they "buy" from defendant by providing their PII, and that the PII 
constitutes valuable property that is exchanged not only for defendant's 
products and services, but also in exchange for defendant's promise to 
employ commercially reasonable methods to safeguard the PII that is 
exchanged. As a result, defendant's role in allegedly contributing to the   
breach of plaintiff's PII caused plaintiff to lose the `value' of their PII, 
in the form of their breached personal data."

was ever supported/refuted in subsequent cases? RockYou settled the case, and I know I'm being a bit lazy here but I figured if anyone knew of some subsequent cases I could look at I'd save some time and ask. I just love this legal theory and although given the history of data breach litigation I'm pretty sure that upper courts wouldn't support id love to be wrong

  • Spokeo v Robbins might be relevant, reemphasizing that "the injury-in-fact requirement requires a plaintiff to show that he or she suffered “an invasion of a legally protected interest” that is “concrete and particularized” and “actual or imminent, not conjectural or hypothetical.”" But also that "A “concrete” injury need not be a “tangible” injury." "A plaintiff does not automatically satisfy the injury-in-fact requirement whenever a statute grants a right and purports to authorize a suit to vindicate it". – user3851 Jun 21 '16 at 16:30

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