Clustered 6 filings across 5 jurisdictions · filing window Mar 15, 2019 → Apr 17, 2019. View entity profile → Other incidents for this victim →
incident inc_99625a044131410c · merge_method deterministic · confidence 100%
Discovered → first regulatory filing
Range of discovered_at dates across filings
CA HI MT OR WA
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.
all State AG
per-filing reported counts
State AGs report only their own residents; bars show per-filing counts.
Earliest sighting first · deep chronology in Litigation Timeline
Dec 7, 2018
When the intrusion reportedly occurred, per the linked filings
Dec 14, 2018
Reported by WASHINGTON AG, CALIFORNIA AG filings
Feb 22, 2019
Reported by OREGON AG filing
flexPATH Strategies, LLC, a retirement plan advisory firm, reported a phishing incident on December 7, 2018, where an unauthorized actor accessed an employee's email account. The breach potentially exposed client employee personal information (PII). flexPATH secured the account, engaged forensic investigators, and offered one year of complimentary credit monitoring via Experian IdentityWorks.
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. Filing summaries shown in the timeline are AI-generated extracts — verify each against its linked source.
flexPATH Strategies reported a data breach to the Hawaii Office of Consumer Protection. The office was notified on 2019/03.15. Breach type: Hackers/Unauthorized Access. 1,573 Hawaii residents were affected. Recovered from the Internet Archive after the notice was removed from the OCP table.
flexPATH Strategies LLC reported a data breach to the Montana Attorney General. The breach was reported on 2019-03-15. The breach occurred from 12/7/2018 to 2/25/2019. 67 Montana residents were affected.
Affected (this filing): 67
flexPath Strategies LLC, a business sector entity reported a phishing incident to the Washington Attorney General. The organization became aware of the incident on 2018-12-14 and filed notice on 2019-03-15. 1,398 Washington residents were affected. 91 days elapsed between awareness and notification. 7 days to identify the breach. 0 days to contain the breach.
Affected (this filing): 1,398
flexPATH Strategies, LLC reported a phishing incident on December 7, 2018, where an unauthorized person accessed an employee's email account. The breach potentially exposed personal information of clients' employees, including data elements within email attachments. The company secured the account, engaged a security firm, and offered one year of complimentary credit monitoring via Experian IdentityWorks.
flexPATH Strategies, LLC reported a data breach to the Oregon Attorney General. The breach was reported on 2019-03-15. The breach occurred during 12/7/2018 - 12/7/2018. The breach was discovered on 2/22/2019. 60,862 individuals were affected. Notice was sent on 3/15/2019.
Affected (this filing): 60,862