The company's lawyers argued in a motion to dismiss that, "A court must dismiss a data breach class action where the Plaintiffs fail to 'adequately allege' damages 'stemming from a data breach.'" Incidents like the Samsung data breach are increasingly prevalent as individuals and companies store more data online. According to a report by the Identity Theft Resource Center (ITRC), 2024 saw 3,158 data breaches—a 70% increase from 2021—resulting in nearly 1.7 billion notifications to potentially affected individuals. ITRC data indicates six megabreaches in 2024, each affecting at least 100 million individuals. The ITRC further suggests that four of these megabreaches could have been prevented through the implementation of multi-factor authentication. Optum, a UnitedHealth subsidiary, acknowledged this in a May 2024 congressional hearing. Each data breach increases the likelihood of subsequent breaches.