DisclosureLens
State AGConfirmed7 filings · 4 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedmoderate sensitivity
Merged incident · 7 filings

Sam's Club — October 2020 breach

Clustered 7 filings across 4 jurisdictions · filing window Nov 20, 2020 Dec 22, 2020. View entity profile → Other incidents for this victim →

Determination

Confirmed

Members

7 filings

States

4

Affected · reported

418

First → last filing

Nov 20, 2020 Dec 22, 2020

Merge confidence

100%

incident inc_1197e2aada0f4f81 · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 7 regulatory filings. The filings describe unauthorized access. Intrusion Oct 20, 2020–Nov 19, 2020, discovered Nov 1, 2020 — the first regulatory filing landed 19 days later. 418 individuals reported across the linked filings. Data reported: Financial account, Credentials, and Identity (basic). Notifications rolled out on a 32-day schedule across 7 filings beginning Nov 20, 2020. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
19days

Discovered → first regulatory filing

Discovery variance
18days

Range of discovered_at dates across filings

Filing span
32days

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 clocksMaine ME AG ≤30d · 30dFull clock table in Litigation Timeline

Incident timeline

Oct 20, 2020breach begins
Nov 1, 2020discovered · members disagree
notification delay · 19 days
Nov 20, 2020first filing
Dec 22, 2020most 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. NOV 20IN AGIN AG noticefirst filing · states nationwide total 156day 0
  2. DEC 10IN AGIN AG noticestates nationwide total 418+20d
  3. DEC 10ME AGME AG noticestates nationwide total 418+20d
  4. DEC 10MT AGMT AG notice1 MT residents+20d
  5. DEC 18NH AGNH AG notice1 NH residents+28d
  6. DEC 18IN AGIN AG noticestates nationwide total 137+28d
  7. DEC 22NH AGNH AG noticemost recent · 1 NH residents+32d
  8. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Oct 20, 2020
IN AG
Discovered
Nov 1, 2020MT AGNov 10, 2020ME AG + NH AGNov 19, 2020NH AGfilings disagree on discovery
Data types
Credentials · Financial account · Identity (basic)
ME AG + MT AG + NH AG
Attack vector
Unauthorized Access
ME 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)

418

Sum of filed state slices

12· 2.9% of stated

97% of the stated total lives in states whose filings carry no count — the dashed share shrinks as filings land.

US418
IN8
ME2
MT1
NH1

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 filing7 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
Reviewed
operator-reviewed Jun 12, 2026 · at least one link edge was human-adjudicated
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

32 days

Cadence

~1 / 5.3d

vs. multi-state median

4.0× 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

The Disclosure Clock is a weekly briefing on what landed in the disclosure record, and the gap between the criminals' post and the regulator's filing — measured on the whole record, with the method shown.

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