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State AGConfirmed3 filings · 3 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 3 filings

Penn, LLC — November 2019 breach

Clustered 3 filings across 3 jurisdictions · filing window Mar 15, 2022 → Mar 18, 2022. View entity profile → Other incidents for this victim →

⚠ 2 cross-filing discrepancies →Merge100%

Determination

Confirmed

Members

3 filings

States

3

Affected · reported

320

First → last filing

Mar 15, 2022 → Mar 18, 2022

Merge confidence

100%

incident inc_9ac150f09151403e · merged by deterministic · confidence 100%

Part of the FreeStyle Solutions supply-chain incident (2022) — at least 12 organizations filed notifications naming this third party.
Confirmed breach. Merged as one breach: 3 regulatory filings. The filings describe malware. Intrusion Nov 1, 2019–Feb 2, 2022, discovered Feb 2, 2022 — the first regulatory filing landed 41 days later. 320 individuals reported across the linked filings. Data reported: Identity (basic), Financial account, Financial credentials, and 1 more. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
41days

Discovered → first regulatory filing

Discovery variance
13days

Range of discovered_at dates across filings

Filing span
3days

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 · 28dFull clock table in Litigation Timeline

Sensitive data

financial_credentials

Incident timeline

Nov 1, 2019breach begins
Feb 2, 2022discovered · members disagree
notification delay · 41 days
Mar 15, 2022first filing
Mar 18, 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. MAR 15DE AGDE AG noticefirst filing · no count statedday 0
  2. MAR 15ME AGME AG notice127 affectedday 0
  3. MAR 18NH AGNH AG noticemost recent · 193 NH residents+3d
  4. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Sep 1, 2021 – Feb 2, 2022
DE AG
Discovered
Feb 2, 2022DE AG + NH AGFeb 15, 2022ME AGfilings disagree on discovery
Data types
Financial account · Financial credentials · Identity (basic) · PII
DE AG + NH AG + ME AG
Attack vector
Ransomware
DE AG

Each fact cites the member filing that establishes it; when filings conflict, every value shows with its source.

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 filing3 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

3 days

Cadence

~1 / 1.5d

vs. multi-state median

2.7× 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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