Premera Blue Cross has once again beaten back some state law fraud and contract claims stemming from a 2015 data breach that exposed the sensitive information of about 11 million customers and employees (In re Premera Blue Cross Customer Data Sec. Breach Litig., 2017 BL 39722, D. Or., No. 3:15-md-2633, 2/9/17).

Judge Michael H. Simon of the U.S. District Court for the District of Oregon Feb. 9 dismissed claims by a class of individuals who claimed the insurer actively concealed its vulnerabilities to the data breach. Additionally, the court dismissed claims that the insurer breached terms of a...