A September 21, 2010 ruling of the Maine Supreme Judicial Court appears to have ended the class action litigation involving the Maine-based supermarket chain Hannaford Bros. Co. Hannaford experienced a breach involving information regarding a reported 4.2 million credit and debit card accounts that had been intercepted while the information was being transmitted to the company’s central computer systems, resulting in more than 20 class actions that were consolidated and transferred to a district court in Maine. In 2009, the district court dismissed most of the class action claims based on a variety of theories, including that there was no breach of implied warranty, no breach of a confidential relationship, or no failure to advise customers of a data breach. Significantly, the court said that, in order to withstand a motion to dismiss, plaintiffs must demonstrate that they faced actual damages. But, the district court stayed its dismissal order in order to ask the Maine Supreme Judicial Court to address whether, under Maine law, “time and effort spent mitigating or averting harm… is alone sufficient to recover damages.” The Maine court concluded that, under Maine law, negligence claims do not provide a basis to “compensate individuals for the typical annoyances or inconveniences that are part of everyday life,” such as expending time and effort to mitigate against risks related to the Hannaford breach.