DisclosureLens
All incidentsView linkage analytics →Get the evidence package — $79what’s inside →
HHS OCRState AGConfirmed2 filings · 2 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 2 filings

Zoe Therapy Services — October 2021 breach

Clustered 2 filings across 2 jurisdictions · filing window Feb 23, 2022 → Mar 3, 2022. View entity profile → Other incidents for this victim →

⚠ 1 cross-filing discrepancy →Merge100%

Determination

Confirmed

Members

2 filings

States

2

Affected · reported

1,100

First → last filing

Feb 23, 2022 → Mar 3, 2022

Merge confidence

100%

incident inc_608ec67e1fce4ea2 · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 2 regulatory filings. The filings describe unauthorized access. Intrusion Oct 6, 2021, discovered Nov 5, 2021 — the first regulatory filing landed 110 days later. 1,100 individuals reported across the linked filings. Data reported: Government ID, PHI, Health (basic), and 2 more. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Notification delay
110days

Discovered → first regulatory filing

Filing span
8days

Time between earliest and latest filing

Not recorded for this incident

Discovery variance · Leak precedence · Materiality delta · SEC filing delay — no leak-site claim in this cluster; no SEC 8-K in this cluster; needs two dated filings.

Regulatory clocksHIPAA✓ HHS notifiedFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

Oct 6, 2021breach begins
Nov 5, 2021discovered
notification delay · 110 days
Feb 23, 2022first filing
Mar 3, 2022most 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. FEB 23HHS OCRHHS OCR noticefirst filing · states nationwide total 1,100day 0
  2. MAR 3NH AGNH AG noticemost recent · 1 NH residents+8d
  3. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Oct 6, 2021
NH AG
Discovered
Nov 5, 2021· 30d undetected
NH AG
Data types
Financial account · Health (basic) · Identity (basic) · Government ID · PHI
HHS OCR + NH AG
Attack vector
Unauthorized Access
HHS OCR

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)

1,100

Sum of filed state slices

1· 0.1% of stated

100% of the stated total lives in states whose filings carry no count — the dashed share shrinks as filings land.

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 filing2 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

8 days

vs. multi-state median

1.0× faster

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.

Weekly. Double opt-in, one-click unsubscribe, and the address goes nowhere else.