The First Circuit recently affirmed a Puerto Rico district court’s ruling dismissing a class action suit arising from a 2019 ransomware attack against a hospital in which 522,493 patients’ personally identifiable information (“PII”) and protected health information (“PHI”) was allegedly accessed by hackers, albeit in “encrypted” form. See Santos-Pagán v. Bayamon Medical Center, No. 24-2018, 2026 WL 1693930 (1st Cir. June 11, 2026).
Continue Reading First Circuit Scrutinizes Causation Issues to Find No Article III Standing in Data Breach CaseNathan Lange
Nathan Lange is an associate in the firm’s Washington office, working primarily in the commercial litigation and class action litigation practice groups. Nathan has particular experience in dispositive motions practice, jurisdictional issues, fact discovery, and settlement mechanics. In addition, Nathan represents clients facing actual or threatened consumer arbitrations, including in the mass arbitration context.
Before practicing law, Nathan had a career in energy trading, including a variety of executive, managerial, analytical, and quantitative roles. He regularly leverages his quantitative background and expertise in data analysis where applicable in his legal work for clients.
Colorado Federal Court Dismisses Data Breach Class Action for Lack of Article III Standing
By Nathan Lange on
A Colorado federal judge recently granted a motion to dismiss a putative class action against two healthcare software companies arising from a 2022 data breach in which a threat actor allegedly accessed personally identifiable information (“PII”) and protected health information (“PHI”) in “over 250,000 patient records.” See Henderson v. Reventics, LLC, 2024 WL 5241386 (D. Colo. Sept. 30, 2024).
Continue Reading Colorado Federal Court Dismisses Data Breach Class Action for Lack of Article III Standing