Another court has dismissed a data breach suit for lack of standing.  In Galaria v. Nationwide Mutual Insurance Co., plaintiffs alleged that they had incurred and would continue to incur damages such as increased risk of identity theft as a result of a data breach at Nationwide.  The U.S. District Court for the Southern District of Ohio, however, ruled that plaintiffs’ allegations were insufficient to establish standing under Article III of the Constitution, as they failed to show an imminent injury.  But in the process, the court highlighted two splits in the courts related to data breach lawsuits:  whether an increased risk of identity theft of fraud is sufficient to establish standing, and whether personally identifiable information has any “inherent monetary value.”