Compliance Engineer

Negligence - data breach - standing. U.S. District Court Where plaintiffs have brought a putative class action alleging that the defendant, their former employer, failed to safeguard their private data, resulting in a data breach that compromised their private information, the plaintiffs have standing to pursue monetary and equitable relief because they have sufficiently alleged that the defendant's conduct led to the material risk of the future misuse of their data and a separate concrete injury caused by their exposure to that risk. "Plaintiffs... bring this putative class action lawsuit alleging that their former employer, defendant Sensata Technologies, Inc., failed to safeguard their private data, resulting in a data breach that compromised their private information and caused them various forms of harm. The operative complaint asserts claims for negligence, breach of contract, unjust enrichment, declaratory judgment, and for violations of the California Unfair Competition Law, California Consumer Privacy Act, California Consumer Records Act, and Massachusetts Consumer Protection Act, M.G.L.c. 93A. Pending before the Court is Sensata's motion to dismiss for lack of standing and for failure to state a claim under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). "For the reasons that follow, that motion will be granted in part and denied in part. The plaintiffs have standing to pursue monetary and equitable relief because they have sufficiently alleged that Sensata's conduct led to the material risk of the future misuse of their data and a separate concrete injury caused by their exposure to that risk. They have alleged plausible claims for negligence, breach of an implied contract, unjust enrichment, and for violations of California's Consumer Privacy Act, Consumer Records Act, and Unfair Competition law. Those claims will proceed to discovery. The plaintiffs' claims for violations of Chapter 93A and the Declaratory Judgment Act will, however, be dismissed... "The consolidated complaint, taken as a whole, adequately alleges a material risk of future misuse... "Having alleged a material risk of future harm and separate concrete harms caused by their exposure to that risk, the plaintiffs have adequately pled an injury in fact for Article III standing purposes. And because the complaint alleges that Sensata's actions led to the Data Breach that exposed the plaintiffs' sensitive Private Information, both the material risk of future harm and the monetary harms caused by that risk are fairly traceable to Sensata's conduct... "In sum, the plaintiffs have adequately alleged that the material risk of future misuse of their Private Information, and the economic harm resulting from that risk, are injuries in fact traceable to Sensata's conduct. Those injuries may be redressed by damages, restitution, a declaratory judgment, and orders compelling Sensata to address the inadequacies in its data security, pay for the plaintiffs' continued credit monitoring services, and provide additional information about the scope of the Data Breach. Accordingly, the plaintiffs have sufficiently pled Article III standing... "Count I asserts that Sensata's negligent failure to employ sufficient data security practices or provide adequate notice of the Data Breach caused harm to the plaintiffs. This harm, they allege, consists of the actual misuse of their data; the risk of future fraud and misuse of that data; lost time spent mitigating present and imminent misuse; a diminution in the value of their Private Information; and emotional distress in the form of anxiety, fear, and sleep disruption. The plaintiffs claim that, as a result of this harm, they have suffered and will continue to suffer compensable damages in the form of lost time spent mitigating the effects of the Data Breach, in addition to annual $200 payments for credit and identity theft monitoring for a minimum of five years... "Having carefully considered the reasoning in Portier [v. NEO Tech. Sols., No. 17-cv-30111-TSH, 2019 WL 7946103, at *12 (D. Mass. Dec. 31, 2019)], this Court agrees that the Supreme Judicial Court would likely hold that the economic loss rule does not bar negligence claims in data breach cases where an employer has required its employees to submit their private information as a condition of employment, retained control over that information, and allegedly breached a common law duty of care to protect such information. Because the plaintiffs have adequately alleged that Sensata collected and stored their Private Information as a condition of their employment, and then breached multiple non-contractual duties to, among other things, 'exercise reasonable care in obtaining, retaining, securing, safeguarding, deleting, and protecting' that information, the economic loss doctrine does not apply... Count I will therefore not be dismissed... "... Sensata argues, and the Court agrees, that the plaintiffs' implied-in-fact theory must fail because the consolidated complaint does not adequately allege an agreement between the parties... "The consolidated complaint does, however, sufficiently state a claim for a breach of contract implied in law... "The consolidated complaint plausibly states a claim of unjust enrichment... "In Count VII, the plaintiffs assert a claim under Massachusetts' Consumer Protection Act, M.G.L.c. 93A. Sensata contends, and the Court agrees, that this claim must be dismissed because all six plaintiffs are former employees of Sensata, and Chapter 93A does not apply to claims made by an employee against an employer arising out of the employment relationship... The plaintiffs do not meaningfully dispute that their status as former employees of Sensata forecloses their Chapter 93A claim. Accordingly, Count VII will be dismissed. "Count VIII seeks a declaratory judgment under the Declaratory Judgment Act, 28 U.S.C. §2201 et seq. Because a declaratory judgment is 'not a cause of action,' but a form of relief, the plaintiffs' standalone claim for declaratory relief must be dismissed. Buck v. Am. Airlines, Inc., 476 F.3d 29, 33 n.3 (1st Cir. 2007). That dismissal will not, however, affect the plaintiffs' ability to seek a declaratory judgment as relief for their other properly pled claims... "For the foregoing reasons, Sensata's motion to dismiss, ECF 22, is granted in part and denied in part. Counts VII and VIII are dismissed, and Counts I, II, III, IV, V, and VI remain." In Re Sensata Technologies Data Breach Litigation (Lawyers Weekly No. 02-512-26) (40 pages) (Kobick, J.) (Docket No. 1:25-cv-11726-JEK) (Sept. 30, 2026).

Attleboro 2024 non-profits ranked by highest total revenue. Local Union 104 Occupational Safety Health And Education Trust Fund was the highest-revenue non-profit in Attleboro, Massachusetts in 2024, with $9,060,145 in total revenue. Attleboro had 47 non-profits with available 2024 Form 990-series total revenue data; the 10 with the highest reported revenues are shown below. Among those organizations, average reported total revenue was $1,031,801. Those organizations reported $48,494,650 in combined total revenue. The ranking reflects non-profits with available Form 990-series total revenue data that met the ranking's data criteria and may not include every non-profit in the city. The ranking is based on IRS Form 990 filings, the annual information returns most tax-exempt organizations file with the IRS. The form includes reported revenue, expenses, assets, governance information and compensation paid to certain people, making it a public source for comparing large tax-exempt organizations' finances. The figures reflect what each organization reported for its filing year, including total revenue, contributions, government grants, compensation, the number of employees and assets at the start and end of the year. Because nonprofits can differ by mission, structure and accounting period, the totals are best read as reported financial measures, not as a direct measure of local charitable activity. Several ranked non-profits reported government grant revenue in 2024. Beta Community Partnerships Inc reported $8,464,678 in government grant revenue, representing 96.3% of its total revenue. Rotch-Jones-Duff House And Garden Museum Inc received $235,295 in government grants, making up 19.3% of its total revenue. Hebron Food Pantry Inc reported $25,500 in government grant revenue, accounting for 4.9% of its total revenue. Among the non-profits shown, Local Union 104 Occupational Safety Health And Education Trust Fund reported $1,012,225 in reportable compensation from related organizations and $444,097 in other compensation reported on the filing. Beta Community Partnerships Inc reported $349,945 in reportable compensation from related organizations and $10,240 in other compensation reported on the filing. The Attleboro Young Mens Christian Association reported $311,538 in reportable compensation from related organizations and $37,607 in other compensation reported on the filing. Several organizations reported substantial contribution revenue and changes in asset balances. Beta Community Partnerships Inc reported $8,529,839 in total contributions in 2024. Attleboro Young Mens Christian Association reported $2,603,296 in total contributions, and The Health Initiative Inc reported $4,530,149 in total contributions. Asset balances at Local Union 104 Occupational Safety Health And Education Trust Fund rose from $12,957,124 at the beginning of the year to $14,752,032 at year-end, an increase of 13.9%. The Health Initiative Inc reported an asset balance change from $15,212,210 to $18,237,507, a 19.9% increase. Ipswich Local News Inc experienced a decrease in asset balances, from $324,427 to $229,361, a 29.3% decline. Several organizations experienced changes in total revenue compared to the prior year. Local Union 104 Occupational Safety Health And Education Trust Fund increased its total revenue from $7,047,258 in 2023 to $9,060,145 in 2024, an increase of $2,012,887 or 28.6%. Beta Community Partnerships Inc grew its total revenue from $7,145,726 in the prior year to $8,789,316 in 2024, an increase of $1,643,590 or 23%. Attleboro Young Mens Christian Association increased its total revenue from $6,302,722 to $8,231,419, a $1,928,697 rise, up 30.6%. The Health Initiative Inc saw total revenue decrease to $6,646,316 from $7,787,773, a decrease of $1,141,457 or 14.7%. Rotch-Jones-Duff House And Garden Museum Inc increased to $1,218,446 from $818,392, up $400,054 or 48.9%. Sensata Technologies Foundation Inc had a total revenue of $827,139, up from $643,297, a $183,842 increase, up 28.6%. Ipswich Local News Inc recorded $520,025, up from $480,015, a rise of $40,010 or 8.3%. Hebron Food Pantry Inc increased to $518,144 from $395,135, a $123,009 increase, up 31.1%. Attleboro Corporate Center Association Inc was up to $6,751,926 from $5,807,624, an increase of $944,302 or 16.3%. Tax-exempt organizations include a wide range of groups, such as charities, foundations, educational institutions and other mission-driven organizations. Under IRS rules, 501(c)(3) organizations must be organized and operated for exempt purposes, and their earnings cannot benefit private shareholders or individuals. Top 10 Non-Profits by Total Revenue in Attleboro (2024) | Rank | Organization | Total revenue | | 1 | Local Union 104 Occupational Safety Health And Education Trust Fund | $9,060,145 | | 2 | Beta Community Partnerships Inc | $8,789,316 | | 3 | Attleboro Young Mens Christian Association | $8,231,419 | | 4 | Attleboro Corporate Center Association Inc | $6,751,926 | | 5 | The Health Initiative Inc | $6,646,316 | | 6 | Woodlawn-North Purchase Cemeteries Association | $1,478,596 | | 7 | Rotch-Jones-Duff House And Garden Museum Inc | $1,218,446 | | 8 | Sensata Technologies Foundation Inc | $827,139 | | 9 | The Ipswich Local News Inc | $520,025 | | 10 | Hebron Food Pantry Inc | $518,144 |