The U.S. Court of Appeals for the Seventh Circuit (the “7th Circuit”) recently issued an opinion in Heather Dieffenbach, et al. v. Barnes & Noble, Inc. that is potentially concerning for current and potential defendants in class action claims related to data breaches. The case relates to a 2012 incident where Barnes & Noble discovered
Barnes & Noble
Data Breach Class Action Dismissed for Not Establishing Economic Injury
By Jeffrey L. Poston & Brandon C. Ge on
Posted in Data Breach, Litigation
Earlier this week, a federal Illinois court dismissed a class action against book retailer Barnes & Noble that alleged breach of contract, invasion of privacy, and violations of state consumer fraud and breach reporting laws. The case, dismissed for failing to establish economic harm, marks another data point in demarcating actionable data breaches and highlights…