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State AGConfirmed12 filings · 11 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedmoderate sensitivity
Merged incident · 12 filings

Totally Promotional — November 2023 breach

Clustered 12 filings across 11 jurisdictions · filing window Oct 16, 2024 → Nov 25, 2024 (dated filings only). View entity profile → Other incidents for this victim →

⚠ 2 cross-filing discrepancies →Merge100%

Determination

Confirmed

Members

12 filings

States

11

Affected · reported

39,024

First → last dated filing

Oct 16, 2024 → Nov 25, 2024

Merge confidence

100%

incident inc_baa8643f8eec417b · merged by human · confidence 100%

Confirmed breach. Merged as one breach: 12 regulatory filings. The filings describe unauthorized access. Intrusion Nov 20, 2023–Oct 20, 2024, discovered Nov 20, 2023. 39,024 individuals reported across the linked filings. Data reported: Identity (basic), Financial account, PCI, and 1 more. Notifications rolled out on a 40-day schedule across 11 dated filings beginning Oct 16, 2024. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Discovery variance
298days

Range of discovered_at dates across filings

Filing span
40days

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 bdayWashington✗ WA AG >90dMaine⏱ ME AG >30d · 33dDate basis✓ Clock withheld · confirmation dateSouth Carolina✓ SC CRA notice dueFull clock table in Litigation Timeline

Incident timeline

Nov 20, 2023breach begins
Nov 20, 2023discovered · members disagree
Oct 16, 2024first dated filing
Nov 25, 2024most 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. OCT 1IL AGIL AG noticefiling day not on record · no count stated—
  2. OCT 16CA AGCA AG noticefirst filing · no count statedday 0
  3. OCT 16VT AGVT AG noticeno count statedday 0
  4. OCT 16MA AGMA AG notice724 MA residentsday 0
  5. OCT 16IN AGIN AG noticestates nationwide total 39,024day 0
  6. OCT 16NH AGNH AG notice155 NH residentsday 0
  7. OCT 16WA AGWA AG noticestates nationwide total 546day 0
  8. OCT 16ME AGME AG noticestates nationwide total 39,024day 0
  9. OCT 16OR AGOR AG noticestates nationwide total 39,024day 0
  10. OCT 16MT AGMT AG notice170 MT residentsday 0
  11. OCT 17SC AGSC AG notice1,124 SC residents+1d
  12. NOV 25CA AGCA AG noticemost recent · no count stated+40d
  13. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Nov 20, 2023 – Jul 18, 2024
CA AG
Discovered
Nov 20, 2023IL AGJul 10, 2024CA AG + VT AG + NH AG +3Sep 13, 2024ME AG + OR AGfilings disagree on discovery
Data types
Financial account · Identity (basic) · PCI · PII
CA AG + VT AG + WA AG +5
Attack vector
Unauthorized Access
CA 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)

39,024

Sum of filed state slices

3,122· 8.0% of stated

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

US39,024
SC1,124
IN788
MA724
MT170
ME160
NH155
WA1

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 filing12 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

40 days

Cadence

~1 / 4d

vs. multi-state median

6.7× 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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