DisclosureLens
HHS OCRState AGConfirmed6 filings · 4 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 6 filings

Vimly Benefit Solutions, Inc. — August 2019 breach

Clustered 6 filings across 4 jurisdictions · filing window Dec 13, 2019 Dec 19, 2019. View entity profile → Other incidents for this victim →

Determination

Confirmed

Members

6 filings

States

4

Affected · reported

182,947

First → last filing

Dec 13, 2019 Dec 19, 2019

Merge confidence

100%

incident inc_7c6b8da1ccc24c76 · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 6 regulatory filings. The filings describe social engineering. Intrusion Aug 16, 2019–Aug 21, 2019, discovered Aug 19, 2019 — the first regulatory filing landed 116 days later. 182,947 individuals reported across the linked filings. Data reported: Government ID, PHI, Health (basic), and 1 more. Notifications rolled out on a 6-day schedule across 6 filings beginning Dec 13, 2019. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
116days

Discovered → first regulatory filing

Discovery variance
2days

Range of discovered_at dates across filings

Filing span
6days

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 clocksHIPAA HHS notifiedMassachusetts MA credit monitoring dueFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

Aug 16, 2019breach begins
Aug 19, 2019discovered · members disagree
notification delay · 116 days
Dec 13, 2019first filing
Dec 19, 2019most 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. DEC 13HHS OCRHHS OCR noticefirst filing · states nationwide total 182,947day 0
  2. DEC 18MA AGMA AG notice4 MA residents+5d
  3. DEC 19MT AGMT AG notice4 MT residents+6d
  4. DEC 19OR AGOR AG noticestates nationwide total 46,299+6d
  5. DEC 19WA AGWA AG notice91,807 WA residents+6d
  6. DEC 19MA AGMA AG noticemost recent · 1 MA residents+6d
  7. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Aug 16, 2019Aug 21, 2019
MT AG
Discovered
Aug 19, 2019WA AGAug 21, 2019MT AGfilings disagree on discovery
Data types
Health (basic) · Identity (basic) · Government ID · PHI
HHS OCR + WA AG + MT AG +1
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)

182,947

Sum of filed state slices

91,815· 50.2% of stated

50% of the stated total lives in states whose filings carry no count — the dashed share shrinks as filings land.

US182,947
WA91,807
MA4
MT4

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 filing6 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

6 days

Cadence

~1 / 1.2d

vs. multi-state median

1.3× 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.

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