Schmitt v. SN Servicing Corporation, an Alaska Corporation

CourtDistrict Court, N.D. California
DecidedAugust 9, 2021
Docket3:21-cv-03355
StatusUnknown

This text of Schmitt v. SN Servicing Corporation, an Alaska Corporation (Schmitt v. SN Servicing Corporation, an Alaska Corporation) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schmitt v. SN Servicing Corporation, an Alaska Corporation, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 DESIREE SCHMITT, et al., Case No. 21-cv-03355-WHO

8 Plaintiffs, ORDER DENYING IN PART AND 9 v. GRANTING IN PART MOTION TO DISMISS WITH LEAVE TO AMEND 10 SN SERVICING CORPORATION, AN ALASKA CORPORATION, Re: Dkt. No. 14 11 Defendant.

12 13 Plaintiffs Desiree Schmitt and James Furth bring this lawsuit against defendant SN 14 Servicing Corporation (“SNSC”) on behalf of a nationwide class of impacted borrowers for claims 15 arising out of a data breach incident that occurred on SNSC’s system in late 2020. On SNSC’s 16 motion to dismiss, I find that although plaintiffs can assert California law claims as Ohio residents 17 given allegations that SNSC’s principal place of business is in California and that they were 18 harmed by critical decisions SNSC made in California, they fail to plausibly plead the elements of 19 those claims. The negligence claim fails because they do not allege that SNSC had a legal duty to 20 protect the kind of information that was revealed in the data breach. For the same underlying 21 reason, the invasion of privacy claim fails because they do not to allege a serious invasion of a 22 protected privacy interest. And the conclusory allegations they provide are insufficient to state a 23 claim for violation of California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code § 24 17200 et seq. For the “unlawful” prong, they simply allege that SNSC violated five statutes, 25 without pleading with particularity how the facts of this case pertain to each specific statute and 26 whether the statute can form a basis for a UCL claim. For the “unfair” prong, they do not 27 sufficiently plead policy considerations based on California privacy statutes to satisfy either the 1 part and GRANTED in part with leave to amend. 2 BACKGROUND 3 SNSC is a financial services corporation that specializes in servicing of residential, small 4 balance commercial, consumer, and unsecured loans. Complaint (“Compl.”) [Dkt. No. 1-1] ¶ 16. 5 It is incorporated in Alaska, with a principal place of business in Eureka, California. Id. ¶ 3. 6 Plaintiffs Desiree Schmitt and James Furth are residents of Ohio and were customers of SNSC’s 7 services. Id. ¶¶ 1–2. 8 On or about October 14, 2020, a ransomware-threat group known as “Mount Locker” (the 9 “Unauthorized Party”) deployed ransomware into SNSC’s system and successfully acquired a 10 number of digital files maintained by SNSC (hereinafter the “data breach” incident). Id. ¶ 62. 11 According to a third-party cybersecurity forensics investigator hired by SNSC, the exfiltration of 12 data from SNSC by the Unauthorized Party ended on or about October 15, 2020. Id. ¶ 17. 13 Plaintiffs allege that the Unauthorized Party was able to exfiltrate the “personal and financial 14 information” of approximately 20,155 borrowers, including citizens of the State of California. Id. 15 ¶¶ 18–19. Despite learning of the data breach on or around October 15, 2020, SNSC did not send 16 a “Data Beach Notification” letter to plaintiffs and class members until January 14, 2021. Id. ¶ 20; 17 see id., Ex. 1.1 18 The Data Breach Notification letter, which Schmitt and Furth claim they received, states 19 that “the preliminary investigation revealed that the data acquired by the Unauthorized Party 20 includes March 2018 billings statements and fee notices that contain the borrower’s personal and 21 financial information including, among other information, borrower names, addresses, loan 22 numbers, balance information, and billing information such as charges assessed, owed, and/or 23 paid.” Id. ¶¶ 22, 40, 45. The Data Breach Notification letter further states that “SNSC is still in 24 the process of conducting an investigation of the incident to determine if additional personal and 25 financial information pertaining to [plaintiffs] was exfiltrated.” Id. ¶¶ 40, 45. In a separate 26 1 This case was removed from San Francisco County Superior Court. The Data Breach 27 Notification letter is not attached to the Complaint submitted along with SNSC’s Notice of 1 January 14, 2021 letter to the New Hampshire Attorney General, SNSC stated that “it had hired a 2 third party e-discovery vendor to conduct a ‘data mining’ review of the documents that were 3 identified to have been exfiltrated to determine whether additional personal and financial 4 information was compromised.” Id. 5 Plaintiffs allege that personal and financial information is “such a valuable commodity to 6 identity thieves that once information has been compromised, criminals often trade the 7 information on the ‘cyber black-market’ for years.” Id. ¶ 34. Accordingly, they contend, there is 8 a “strong probability” that their stolen information is, or soon will be, on the cyber black-market, 9 placing them and other class members “at an increased risk of fraud and identity theft for many 10 years into the future.” Id. ¶ 35. As a result of the data breach, and as recommended by the Data 11 Breach Notification letter, plaintiffs assert that they must now be “vigilant and review their credit 12 reports for incidents of identity theft, and educate themselves about security freezes, fraud alerts, 13 and other steps to protect themselves against identity theft.” Id. ¶ 24. 14 In particular, Schmitt alleges that she “purchased credit monitoring with Lifelock at an 15 annual cost of more than $200.00, as well as LastPass password manager, which is a monthly 16 password manager and password vault application subscription service that costs $3.00 per month, 17 and YubiKey password protection at a cost of more than $90.00.” Id. ¶ 41. Furth contends that he 18 too “purchased Lifelock identify protection at an annual cost of $99.48” after the data breach. Id. 19 ¶ 46. Both claim that they have “spent time and energy protecting and monitoring [their] identity 20 and credit” and will have to “spend additional time and energy in the future continuing to monitor 21 and protect [their] identity and credit.” Id. ¶¶ 42, 47. Schmitt alleges that she “spent at least 10 22 hours changing hundreds of passwords related to her business and personal accounts.” Id. ¶ 42. 23 Both allege that they “suffered anxiety, emotional distress, and loss of privacy” as a result of the 24 data breach. Id. ¶¶ 42, 47. 25 Plaintiffs claim that SNSC started to undertake the “basic steps” recognized in the industry 26 to protect their and other class members’ personal and financial information only after an 27 Unauthorized Party was able to exfiltrate a large amount of data. Id. ¶ 23. As the Data Breach 1 incident “by replacing email filtering tools, malware software, and Internet monitoring tools with 2 more robust solutions that utilizes AI to detect and block known and newly introduced malware, 3 and block all inbound and outbound Internet, email, and network traffic to foreign countries.” Id. 4 Because of SNSC’s failure to “create, maintain, and/or comply with necessary cybersecurity 5 requirements,” plaintiffs allege that SNSC “was unable to protect borrower’s information and 6 confidentiality, and protect against obvious and readily foreseeable threats to information security 7 and confidentiality or unauthorized access to personal and financial information, resulting in the 8 Data Breach.” Id. ¶ 27. 9 Plaintiffs filed this lawsuit in San Francisco County Superior Court on March 12, 2021, 10 bringing the following three claims on behalf a nationwide class of borrowers impacted by the 11 data breach: (i) negligence; (ii) invasion of privacy; and (iii) relief under the “unlawful” and 12 “unfair” prongs of the UCL. On May 5, 2021, SNSC removed the action to this court and 13 subsequently filed a motion to dismiss for failure to state a claim. Notice of Removal [Dkt. No.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Joel Ruiz v. Gap, Inc.
380 F. App'x 689 (Ninth Circuit, 2010)
Gary Davis v. Hsbc Bank Nevada, N.A.
691 F.3d 1152 (Ninth Circuit, 2012)
Brian O'DOnnell v. Bank of America, National Asso
504 F. App'x 566 (Ninth Circuit, 2013)
Sullivan v. Oracle Corp.
254 P.3d 237 (California Supreme Court, 2011)
Phillip Corvello v. Wells Fargo Bank N.A.
728 F.3d 878 (Ninth Circuit, 2013)
Hill v. National Collegiate Athletic Assn.
865 P.2d 633 (California Supreme Court, 1994)
Pitten v. Jacobs
903 F. Supp. 937 (D. South Carolina, 1995)
In Re Gilead Sciences Securities Litigation
536 F.3d 1049 (Ninth Circuit, 2008)
Lozano v. AT & T Wireless Services, Inc.
504 F.3d 718 (Ninth Circuit, 2007)
Rowland v. Christian
443 P.2d 561 (California Supreme Court, 1968)
Ruiz v. Gap, Inc.
540 F. Supp. 2d 1121 (N.D. California, 2008)
In Re Mattel, Inc.
588 F. Supp. 2d 1111 (C.D. California, 2008)
Lucia v. Wells Fargo Bank, N.A.
798 F. Supp. 2d 1059 (N.D. California, 2011)
In Re Toyota Motor Corp.
785 F. Supp. 2d 883 (C.D. California, 2011)
Khoury v. Maly's of California, Inc.
14 Cal. App. 4th 612 (California Court of Appeal, 1993)
Norwest Mortgage, Inc. v. Superior Court
85 Cal. Rptr. 2d 18 (California Court of Appeal, 1999)
Korea Supply Co. v. Lockheed Martin Corp.
63 P.3d 937 (California Supreme Court, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
Schmitt v. SN Servicing Corporation, an Alaska Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schmitt-v-sn-servicing-corporation-an-alaska-corporation-cand-2021.