Last month, the U.S. District Court for the Northern District of California found that the plaintiffs in the data breach suit against Anthem had alleged cognizable injuries under both California’s Unfair Competition Law (UCL) and New York’s General Business Law (GBL), though the theory differed as to each state. The case stems from a data breach suffered by Anthem, one of the nation’s largest health insurers, and its affiliates between December 2014 and January 2015. The class action plaintiffs claim that Anthem failed to adequately safeguard the personal information of the 80 million customers and employees whose data was stolen by hackers in that breach. The court allowed the claim under the California UCL to proceed on the theory that the plaintiffs had lost the “benefit of the bargain” with Anthem. And the New York GBL claim was permitted based on a “loss of value” in the plaintiffs’ PII, though the court was fuzzy on just what that means.