DisclosureLens
State AGConfirmed7 filings · 6 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 7 filings

Penn, LLC — November 2019 breach

Clustered 7 filings across 6 jurisdictions · filing window Jan 14, 2022 Mar 15, 2022. View entity profile → Other incidents for this victim →

Determination

Confirmed

Members

7 filings

States

6

Affected · reported

227,769

First → last filing

Jan 14, 2022 Mar 15, 2022

Merge confidence

100%

incident inc_f59ea366a1b1439e · merged by human · 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: 7 regulatory filings. Intrusion Nov 1, 2019–Feb 2, 2022, discovered Mar 8, 2021 — the first regulatory filing landed 312 days later. 227,769 individuals reported across the linked filings. Data reported: Identity (basic), Financial account, Financial credentials, and 2 more. Notifications rolled out on a 60-day schedule across 7 filings beginning Jan 14, 2022. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
312days

Discovered → first regulatory filing

Discovery variance
331days

Range of discovered_at dates across filings

Filing span
60days

Time between earliest and latest filing

Not recorded for this incident

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

Regulatory clocksOregon OR AG ≤45dSouth Carolina SC CRA notice dueFull clock table in Litigation Timeline

Sensitive data

financial_credentials

Incident timeline

Nov 1, 2019breach begins
Mar 8, 2021discovered · members disagree
notification delay · 312 days
Jan 14, 2022first filing
Mar 15, 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. JAN 14OR AGOR AG noticefirst filing · states nationwide total 201,000day 0
  2. JAN 25IN AGIN AG noticestates nationwide total 227,769+11d
  3. JAN 25CA AGCA AG noticeno count stated+11d
  4. JAN 25SC AGSC AG notice3,642 SC residents+11d
  5. JAN 25MA AGMA AG notice5,270 MA residents+11d
  6. JAN 27NH AGNH AG notice1,148 NH residents+13d
  7. MAR 15CA AGCA AG noticemost recent · no count stated+60d
  8. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Nov 1, 2019Aug 31, 2021
OR AG
Discovered
Mar 8, 2021CA AG + SC AG + NH AGDec 2, 2021OR AGFeb 2, 2022CA AGfilings disagree on discovery
Data types
Financial account · Financial credentials · Identity (basic) · PCI · PII
CA AG + SC AG + NH AG +1
Attack vector
Unauthorized Access
SC 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

14,088· 6.2% of stated

94% 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
NH1,148

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 filing7 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 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

60 days

Cadence

~1 / 10d

vs. multi-state median

7.5× 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.

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