DisclosureLens
HHS OCRState AGConfirmed8 filings · 8 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 8 filings

ERMI — February 2025 breach

Clustered 8 filings across 8 jurisdictions · filing window May 1, 2026 May 29, 2026. View entity profile → Other incidents for this victim →

Determination

Confirmed

Members

8 filings

States

8

Affected · reported

74,074

First → last filing

May 1, 2026 May 29, 2026

Merge confidence

100%

incident inc_106c084bcd0c47fa · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 8 regulatory filings. Intrusion Feb 15, 2025–Aug 14, 2025, discovered Jul 25, 2025 — the first regulatory filing landed 280 days later (flagged late). 74,074 individuals reported across the linked filings. Data reported: Government ID, Financial account, Health (basic), and 3 more. Notifications rolled out on a 28-day schedule across 8 filings beginning May 1, 2026. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
280days

Discovered → first regulatory filing

Discovery variance
266days

Range of discovered_at dates across filings

Filing span
28days

Time between earliest and latest filing

Not recorded for this incident

Leak precedence · Materiality delta · SEC filing delayno leak-site claim in this cluster; no SEC 8-K in this cluster.

Regulatory clocksMassachusetts MA AG >90dHIPAA HHS notifiedSouth Carolina SC CRA notice dueFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

Feb 15, 2025breach begins
Jul 25, 2025discovered · members disagree
notification delay · 280 days
May 1, 2026first filing
May 29, 2026most recent filing

Dashed segments are unestablished, not zero — they fill in as filings merge into this incident.

Member cascade — every filing about this breach

  1. MAY 1IL AGIL AG noticefirst filing · no count statedday 0
  2. MAY 26CA AGCA AG noticeno count stated+25d
  3. MAY 26MA AGMA AG notice22 MA residents+25d
  4. MAY 26NE AGNE AG noticeno count stated+25d
  5. MAY 26VT AGVT AG notice3 VT residents+25d
  6. MAY 26HHS OCRHHS OCR noticestates nationwide total 74,074+25d
  7. MAY 28TX AGTX AG noticestates nationwide total 74,074+27d
  8. MAY 29SC AGSC AG noticemost recent · 4,360 SC residents+28d
  9. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Feb 15, 2025Aug 14, 2025
CA AG
Discovered
Jul 25, 2025CA AG + MA AG + NE AG +1Apr 17, 2026IL AG + TX AGfilings disagree on discovery
Data types
Financial account · Health (basic) · Identity (basic) · Government ID · PHI · PII
IL AG + MA AG + TX AG +5
Attack vector
Unauthorized Access
CA AG

Each fact cites the member filing that establishes it; when filings conflict, every value shows with its source.

Count reconciliation

per-state reported counts

Nationwide (stated in a filing)

74,074

Sum of filed state slices

13,838· 18.7% of stated

81% of the stated total lives in states whose filings carry no count — the dashed share shrinks as filings land.

US74,074
TX9,453
SC4,360
MA22
VT3

State AGs report only their own residents; teal bars show each state's reported slice. The gray US row is the nationwide total reported in a linked filing.

Evidence ladder — rungs this incident occupies

Leak-site claim

No leak-site claim on record for this incident.

Press / market report

No press coverage linked yet.

State AG / regulator filing8 members

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

No SEC filing or victim statement yet.

Merge provenance

Method
deterministic
Confidence
1.00 · above the 0.85 auto-merge floor
Audit
Every link edge records its method, confidence and model + prompt versions (100% is the strongest edge).

Merges are reversible — a wrong link can be detached with its audit trail intact. How merging works.

Filing velocity

Spread

28 days

Cadence

~1 / 4d

vs. multi-state median

3.5× slower

About this clustering

DisclosureLens links filings into incidents through layered matchers: deterministic rules (same source document, multistate filings of one breach, tight-window same-victim pairs), a weighted-similarity scorer for cross-source candidates, and an operator review queue for everything uncertain. Each link records its own method and confidence — shown per filing in the timeline below. The system defaults to NOT merging when uncertain, because a false merge (collapsing two unrelated breaches) is more harmful than a false split (showing related filings separately); uncertain pairs route to human review instead of auto-merging. This page states only what the linked filings agree on; each filing's own account stays on its own record, linked from the timeline below.

The weekly clock on records like this one

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