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State AGConfirmed10 filings · 10 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 10 filings

Gulshan Management Services — September 2025 breach

Clustered 10 filings across 10 jurisdictions · filing window Jan 1, 2026 → Mar 16, 2026. View entity profile → Other incidents for this victim →

⚠ 1 cross-filing discrepancy →Merge100%

Determination

Confirmed

Members

10 filings

States

10

Affected · reported

377,082

First → last filing

Jan 1, 2026 → Mar 16, 2026

Merge confidence

100%

incident inc_97aa9a5679aa4eff · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 10 regulatory filings. The filings describe a phishing attack. Intrusion Sep 17, 2025–Sep 27, 2025, discovered Sep 27, 2025 — the first regulatory filing landed 96 days later (flagged late). 377,082 individuals reported across the linked filings. Data reported: Government ID, Financial account, Identity (basic), and 1 more. Notifications rolled out on a 74-day schedule across 10 filings beginning Jan 1, 2026. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
96days

Discovered → first regulatory filing

Discovery variance
0days

Range of discovered_at dates across filings

Filing span
74days

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 clocksVermont✗ VT AG >45 bdayMaine✗ ME AG >90d · 101dTexas✗ TX AG >30dSouth Carolina✓ SC CRA notice dueFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

Sep 17, 2025breach begins
Sep 27, 2025discovered
notification delay · 96 days
Jan 1, 2026first filing
Mar 16, 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. JAN 1IL AGIL AG noticefirst filing · no count statedday 0
  2. JAN 5VT AGVT AG noticeno count stated+4d
  3. JAN 5NE AGNE AG noticeno count stated+4d
  4. JAN 5IN AGIN AG noticestates nationwide total 377,082+4d
  5. JAN 5NH AGNH AG notice4,403 NH residents+4d
  6. JAN 6ME AGME AG noticestates nationwide total 377,082+5d
  7. JAN 6IA AGIA AG noticeno count stated+5d
  8. JAN 6SC AGSC AG notice1,414 SC residents+5d
  9. JAN 6MA AGMA AG notice8,750 MA residents+5d
  10. MAR 16TX AGTX AG noticemost recent · states nationwide total 377,082+74d
  11. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Sep 17, 2025 – Sep 27, 2025
VT AG
Discovered
Sep 27, 2025· 10d undetected
IL AG + VT AG + NE AG +5
Data types
Financial account · Health (basic) · Identity (basic) · Government ID
IL AG + MA AG + TX AG +6
Attack vector
Phishing
VT 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)

377,082

Sum of filed state slices

149,284· 39.6% of stated

60% of the stated total lives in states whose filings carry no count — the dashed share shrinks as filings land.

US377,082
TX128,652
MA8,750
IN6,011
NH4,403
SC1,414
ME54

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 filing10 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

74 days

Cadence

~1 / 8.2d

vs. multi-state median

9.3× 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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