Health-care benefits provider Premera Blue Cross failed Aug. 1 to escape a putative class action over a 2015 data breach that compromised sensitive information of approximately 11 million customers and employees (In re Premera Blue Cross Customer Data Sec. Breach Litig., 2016 BL 248329, D. Or., Case No. 3:15-md-2633-SI, 8/1/16).

But Judge Michael H. Simon of the U.S. District Court for the District of Oregon dismissed the fraud-based claims against Premera, saying that the plaintiffs failed to allege specific misrepresentation, concealment or omission. The court granted the plaintiffs leave to replead the fraud-based claims, with “clear articulation...