For the second time this year, the U.S. District Court for the Northern District of California has ruled that state law claims arising from Anthem’s February data breach are preempted by the Employee Retirement Income Security Act (Smilow v. Anthem Life & Disability Ins. Co. (In re Anthem, Inc. Data Breach Litig.), N.D. Cal., No. 5:15-cv-04739-LHK, 11/24/15).
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