A federal district court in Illinois recently held that the plaintiffs in a data breach suit against arts-and-crafts retailer Michaels Stores had standing to sue based on an increased risk of identity theft.  Unlike many courts in recent times, this court found that the Supreme Court’s decision in Clapper vs. Amnesty International USA strictly limiting standing based on allegations of future harm was not directly applicable, since Clapper dealt with a national security matter and constitutional issues.  The court thus indicated that a more liberal view on standing should apply in run-of-the-mill breach cases.  Nevertheless, the court found that the plaintiffs had not sufficiently alleged actual monetary loss, and therefore had failed to state a claim upon which relief could be granted.