Smith v. Specialty Networks LLC
1:24-cv-00286
| E.D. Tenn. | Jul 15, 2025Background
- Plaintiffs filed a class action against Specialty Networks LLC and Prime Imaging, LLC after a major data breach compromising private patient information affecting around 395,866 individuals.
- The breach involved sensitive data including names, Social Security numbers, medical information, and more, with notification to affected individuals beginning August 15, 2024.
- The case was consolidated with five other related actions arising from the same incident, and interim class counsel was appointed.
- Plaintiffs alleged negligence, breach of fiduciary duty, unjust enrichment, and invasion of privacy.
- After mediation with a neutral, the parties reached a settlement, leading to a motion for preliminary approval of the class-wide resolution and related settlement administration appointments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preliminary approval of settlement (Rule 23) | Settlement is fair and adequate | Do not oppose | Settlement preliminarily approved |
| Certification of settlement class | Class meets Rule 23(a) & (b)(3) | Do not oppose | Likely to certify for settlement |
| Approval of class notice | Proposed notice meets legal standards | Do not oppose | Notice plan approved |
| Appointment of class counsel & representatives | Counsel/representatives are adequate | Do not oppose | Appointments affirmed |
Key Cases Cited
- Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (commonality requirement for class actions)
- Amchem Prods. v. Windsor, 521 U.S. 591 (predominance & superiority in Rule 23(b)(3) class actions)
- General Tel. Co. v. Falcon, 457 U.S. 147 (typicality & commonality standards)