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 sued Open AI Global, LLC and affiliated entities, alleging that ChatGPT was marketed as safe and reliable without disclosing risks of inaccurate or harmful outputs. The suit also alleges harms to minors and collection of their data without parental oversight; the release states no monetary penalty or specific remedy imposed.
Texas Attorney General Ken Paxton secured an Assurance of Voluntary Compliance with Lululemon USA Inc. after investigating potential PFAS and consumer representations about product safety. The agreement requires the company to maintain supply-chain chemical standards, verify vendor compliance through testing or certifications, and take corrective action for three years; no monetary penalty is stated.
$3.0M
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$773.0M
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