Texas Attorney General Ken Paxton issued Civil Investigative Demands to Blue Cross Blue Shield of Texas and Conduent Business Services LLC as part of an investigation into a data breach that exposed the protected health information of approximately four million Texans. The breach, which occurred between October 21, 2024 and January 13, 2025, is believed to be the largest in U.S. history. The investigation focuses on Conduent's security measures and BCBS's compliance with state data protection laws.
In-house legal teams should immediately review all vendor, customer, and data processing agreements where Conduent Business Services LLC or similar service providers handle protected health information or sensitive personal data. Focus on clauses governing data security obligations, breach notification timelines and procedures, compliance with state-specific data protection laws (particularly Texas), data processing addendums, and indemnification/liability provisions. Given the investigation into potential negligence and the scale of the breach, contracts may require amendments to mandate stricter security safeguards (e.g., encryption, access controls), explicit adherence to Texas data protection statutes, clearer breach response protocols, and enhanced audit rights to ensure ongoing compliance and allocate risk appropriately.
Entity
Conduent Business Services LLC
Also known as: Conduent
Industry
TechnologyConduent Business Services LLC (Business Associate, NJ) reported a HIPAA breach affecting 42,616 individuals. Breach type: Hacking/IT Incident. Location of breached information: Network Server.
Texas Attorney General Ken Paxton issued a consumer alert warning Texans about scams, fraudulent charities, and illegal price gouging related to severe flooding. The guidance provides resources for verifying charities and reporting suspected fraud or price gouging to the AG's office.
$150.0M
Texas Attorney General Ken Paxton secured a $150 million multistate settlement against 23andMe following a 2023 data breach that exposed genetic and personal data of 6.9 million consumers. The settlement resolves bankruptcy claims and requires enhanced data security, risk assessments, and an independent advisory board, with immediate recovery of $18 million from bankruptcy funds.
Texas Attorney General Ken Paxton opened an investigation into LinkedIn Corporation over allegations that the company advertised and profited from fake or misleading job opportunities ("ghost jobs") on its platform. The investigation focuses on whether LinkedIn misled consumers who paid for Premium subscriptions by failing to disclose that a significant percentage of job postings may be inactive or not genuine hiring opportunities.
$45.0M
Attorney General Ken Paxton secured a $45 million multistate settlement with Block, Inc. (Cash App) for misleading consumers about the safety of its platform and failing to protect users from fraud. The settlement requires Cash App to maintain 24-hour customer support, cease deceptive safety claims, and fulfill its legal duty to investigate and reimburse unauthorized transactions.
$13.0M
Texas Attorney General Ken Paxton secured a settlement with Walmart over deceptive practices in its Spark Driver program. Walmart misrepresented driver pay, including failing to pass on customer tips and altering base pay after drivers accepted offers. The $13 million settlement provides direct payments to affected Texas drivers and requires Walmart to implement honest compensation practices.