DisclosureLens
All incidentsView linkage analytics →Get the evidence package — $7.99what’s inside →
State AGConfirmed16 filings · 11 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 16 filings

Penn, LLC — November 2019 breach

Clustered 16 filings across 11 jurisdictions · filing window Dec 30, 2021 → Mar 18, 2022 (dated filings only). View entity profile → Other incidents for this victim →

⚠ 2 cross-filing discrepancies →Merge100%

Determination

Confirmed

Members

16 filings

States

11

Affected · reported

227,769

First → last dated filing

Dec 30, 2021 → Mar 18, 2022

Merge confidence

100%

incident inc_804d6045cb664ef5 · merged by human · confidence 100%

Part of the FreeStyle Solutions supply-chain incident (2022) — at least 10 organizations filed notifications naming this third party.
Confirmed breach. Merged as one breach: 16 regulatory filings. Intrusion Nov 1, 2019–Feb 2, 2022, discovered Mar 8, 2021 — the first regulatory filing landed 297 days later. 227,769 individuals reported across the linked filings. Data reported: Government ID, Identity (basic), Financial account, and 4 more. Notifications rolled out on a 78-day schedule across 15 dated filings beginning Dec 30, 2021. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
297days

Discovered → first regulatory filing

Discovery variance
344days

Range of discovered_at dates across filings

Filing span
78days

Time between earliest and latest filing

Not recorded for this incident

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

Regulatory clocksMaine⏱ ME AG >30d · 53dWashington⏱ WA AG >30dDate basis✓ Clock withheld · confirmation dateSouth Carolina✓ SC CRA notice dueFull clock table in Litigation Timeline

Sensitive data

authenticationfinancial_credentialsidentity_government

Incident timeline

Nov 1, 2019breach begins
Mar 8, 2021discovered · members disagree
notification delay · 297 days
Dec 30, 2021first dated filing
Mar 18, 2022most recent dated filing

Dashed segments are unestablished, not zero — they fill in as filings merge into this incident. Filings without a recorded filing day, or recorded as filed before the breach they report began, are not placed on this rail.

Member cascade — every filing about this breach

  1. DEC 30ME AGME AG noticefirst filing · states nationwide total 201,000day 0
  2. DEC 30WA AGWA AG notice3,603 WA residentsday 0
  3. JAN 1IL AGIL AG noticefiling day not on record · no count stated—
  4. JAN 14OR AGOR AG noticestates nationwide total 201,000+15d
  5. JAN 24ME AGME AG notice753 affected+25d
  6. JAN 24MT AGMT AG notice602 MT residents+25d
  7. JAN 24DE AGDE AG noticeno count stated+25d
  8. JAN 25CA AGCA AG noticeno count stated+26d
  9. JAN 25IN AGIN AG noticestates nationwide total 227,769+26d
  10. JAN 25SC AGSC AG notice3,642 SC residents+26d
  11. JAN 25MA AGMA AG notice5,270 MA residents+26d
  12. JAN 27NH AGNH AG notice1,148 NH residents+28d
  13. MAR 15DE AGDE AG noticeno count stated+75d
  14. MAR 15ME AGME AG notice127 affected+75d
  15. MAR 15CA AGCA AG noticeno count stated+75d
  16. MAR 18NH AGNH AG noticemost recent · 193 NH residents+78d
  17. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Nov 1, 2019 – Aug 31, 2021
ME AG
Discovered
Mar 8, 2021MT AG + DE AG + CA AG +2Oct 1, 2021WA AGDec 2, 2021ME AG + OR AGFeb 2, 2022IL AG + DE AG + CA AG +1Feb 15, 2022ME AGfilings disagree on discovery
Data types
Authentication · Financial account · Financial credentials · Identity (basic) · Government ID · PCI · PII
ME AG + WA AG + MT AG +5
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)

227,769

Sum of filed state slices

19,046· 8.4% of stated

92% of the stated total lives in states whose filings carry no count — the dashed share shrinks as filings land.

US227,769
MA5,270
IN4,028
SC3,642
WA3,603
NH1,148
ME753
MT602

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 filing16 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
human
Confidence
1.00 · above the 0.85 auto-merge floor
Reviewed
operator-reviewed Oct 22, 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

78 days

Cadence

~1 / 5.6d

vs. multi-state median

13.0× 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.

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