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