On August 25, 2016, in Longenecker-Wells v. Benecard Services, Inc., the Third Circuit affirmed dismissal of negligence and breach of implied contract claims against Benecard Services, Inc. arising from a data breach last year. In early 2015, Benecard's computer systems were compromised and unknown third parties subsequently used plaintiffs' personal information to file fraudulent tax returns to obtain tax refunds. The Third Circuit affirmed dismissal of the negligence claim on the grounds that Pennsylvania's economic loss doctrine barred causes of action "for negligence that result solely in economic damages unaccompanied by physical injury or property damage." The Court also affirmed dismissal of plaintiffs' claim for breach of implied contract on the grounds that the plaintiffs had not pleaded "any company-specific documents or policies from which one could infer an implied contractual duty to protect Plaintiffs' information." Mere allegations that an implied contract arose "from the course of conduct" were insufficient to survive a motion to dismiss. On October 5, 2016, the Third Circuit denied plaintiffs' petition for rehearing.