Lehigh Valley Health Network Pays $800K Penalty to Resolve HIPAA Violations

Posted by Steve Alder

Lehigh Valley Health Network has agreed to settle alleged violations of the HIPAA Rules with the HHS’ Office for Civil Rights (OCR) and will pay an $800,000 financial penalty and adopt a corrective action plan to address identified areas of noncompliance. This is OCR’s 22nd investigation of a ransomware attack to result in a financial penalty for noncompliance with the HIPAA Rules.

OCR launched an investigation after receiving a breach report on May 15, 2026, from Lehigh Valley Health Network about a cybersecurity incident that exposed the protected health information (PHI) of 248,359 individuals. Lehigh Valley Health Network identified suspicious activity within its network in early February 2023 and later confirmed that ransomware was involved. The ALPHV/BlackCat ransomware group breached parts of its network, specifically IT systems related to Delta Medix, a company acquired by Lehigh Valley Health Network in 2021. The ransomware group exfiltrated files containing patient information and issued a ransom demand. The ransom was not paid, and the stolen data was leaked on the ransomware group’s dark web data leak site.

Data stolen and leaked in the incident included names, addresses, dates of birth, Social Security numbers, driver’s license numbers, financial information, diagnoses and conditions, lab results, medications, and treatment information. In addition, photographs of cancer patients receiving radiation oncology treatment were stolen in the incident and leaked online, including photographs of patients who were naked from the waist up. Lehigh Valley Health Network was sued over the data breach and settled the class action litigation for $65 million.

OCR’s investigation identified multiple potential violations of the HIPAA Rules, including two violations of the HIPAA Security Rule. Lehigh Valley Health Network was determined to have failed to conduct a comprehensive and accurate risk analysis to identify risks and vulnerabilities to electronic PHI, and failed to implement policies and procedures for regularly reviewing records of activity in information systems containing ePHI, such as audit logs, access reports, and security incident tracking reports. These failures led to the impermissible disclosure of the ePHI of 248,359 individuals, in violation of the HIPAA Privacy Rule.

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OCR also determined that Lehigh Valley Health Network failed to issue timely notifications to the affected individuals to alert them to the theft of their personal and health information and did not issue a timely notification to the Secretary of the Department of Health and Human Services, in violation of the HIPAA Breach Notification Rule. According to OCR, the intrusion was detected on February 4, 2026, and OCR was notified about the incident on May 15, 2026. The HHS Secretary must be notified about a breach of unsecured protected health information within 60 days of discovery of a breach. While OCR has not stated that it has an active enforcement initiative targeting noncompliance with the HIPAA Breach Notification Rule, a significant number of recent settlements have involved penalties for breach notification failures, including five of the 12 HIPAA settlements announced this year and five settlements last year.

Under the terms of the settlement agreement, in addition to the financial penalty, Lehigh Valley Health Network has agreed to adopt a corrective action plan that includes the requirements to conduct a comprehensive and accurate risk analysis, develop a risk management plan, review and revise its policies and procedures to ensure compliance with the HIPAA Rules, and develop training materials and provide training to its workforce on the HIPAA Rules relative to the performance of individuals’ job duties. OCR will monitor Lehigh Valley Health Network for compliance for a period of three years.

“Failure to conduct an accurate and thorough risk analysis and to undertake regular review of information system activity makes regulated entities attractive targets for cyberattacks,” said OCR Director Paula M. Stannard. “The best defense against cyberattacks is full implementation of the HIPAA Security Rule.”

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GoodRx & Criteo Revised $32 Million Data Privacy Settlement Gets First Approval

Posted by Steve Alder

A revised $32 million settlement has received first approval from the court to resolve class action data breach litigation against GoodRx and Criteo related to the use of website tracking tools on the GoodRx website that disclosed user information to third parties without consent. GoodRx is a Santa Monica, California-based telehealth company that operates a free-to-use platform that tracks prescription drug prices and offers coupons providing discounts on medications. Criteo is a Paris, France-based digital advertising company that offers AI-driven performance marketing and retargeting solutions.

Both companies agreed to settle a consolidated class action complaint alleging unfair business practices and improper sharing of consumer data with digital advertising and analytics companies between 2017 and 2020. The litigation also named other companies as defendants, which are not included in the settlement agreement. The litigation stems from a Federal Trade Commission (FTC) complaint alleging GoodRx unlawfully disclosed the personal and health information of its users in violation of the FTC Act and the FTC’s Health Breach Notification Rule. GoodRx disagreed with the FTC’s allegations; however, the FTC complaint was resolved with a $1.5 million settlement.

On February 2, 2023, the first putative class action lawsuit was filed, followed by other class action complaints against defendants GoodRx, Criteo, Meta and Google. The lawsuits were consolidated into a single complaint – Doe et al. v. GoodRx Holdings, Inc., et al. – which is pending in the United States District Court for the Northern District of California, Oakland Division.

The consolidated lawsuit asserted claims for negligence, negligence per se, intrusion upon seclusion, unjust enrichment, and violations of the California Confidentiality of Medical Information Act, California Invasion of Privacy Act, California Consumers Legal Remedies Act, California Unfair Competition Law, New York’s General Business Law, and Illinois Consumer Fraud and Deceptive Business Practices Act.

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The plaintiffs believe their claims are valid, and the defendants deny the claims in the lawsuit and maintain no laws were violated. After two mediation conferences and subsequent discussions, a settlement was agreed upon that was acceptable to all parties to avoid the cost, distraction, and risks associated with a trial and related appeals. The proposed $25 million settlement was agreed by the plaintiffs and the defendants; however, the settlement was rejected by District Court Judge Araceli Martinez-Olguin, as the parties failed to meet the legal standards for demonstrating that the settlement was fair to consumers.

In response, GoodRx and Criteo agreed to increase the settlement fund by $7 million and formally added Criteo to the settlement agreement. The claims against the other defendants, Meta and Google, are continuing separately. The renegotiated settlement agreement has received preliminary approval from the court. Under the terms of the settlement, GoodRx and Criteo will establish a $32,000,000 settlement fund from which attorneys’ fees and expenses, notification and settlement administration costs, settlement fund account costs, and service awards for the class representatives will be deducted. The remainder of the settlement fund will be paid pro rata to individuals who submit a valid claim. The settlement agreement includes a clause that allows the defendants to cancel the settlement if the number of individuals excluding themselves exceeds an agreed-upon number.

Class members wishing to object to the settlement or opt out must do so by December 29, 2026. Claims must be submitted by the same date, and the final fairness hearing has been scheduled for February 11, 2027.

December 4, 2024: GoodRx Agrees to $25 Million Settlement to Resolve Tracking Technology Lawsuit

GoodRx, a telemedicine platform provider and drug discounter, has agreed to settle a consolidated class action lawsuit for $25 million. The lawsuit was filed in response to its use of website tracking technologies that disclosed website visitor data to third parties such as Meta Platforms, Google, and Criteo for advertising purposes without user consent.

The tracking technologies, also known as pixels, are code snippets that are added to websites to track user interactions. The information gathered on visitors can be used to improve websites and is also transferred to third parties for advertising purposes. The Federal Trade Commission (FTC) investigated GoodRx over the use of tracking tools and determined the FTC Act had been violated. GoodRx had provided repeated assurances to its users that their sensitive data would not be shared with third parties, when the tracking tools on its website shared identifying information, including sensitive health information, with third parties without users’ knowledge or consent. The FTC also alleged a violation of its Health Breach Notification Rule as GoodRx failed to notify users about the data sharing.

GoodRx disagreed with the FTC’s findings, claiming the issue had been addressed almost 3 years before the FTC started investigating and maintains there was no wrongdoing. GoodRx maintains tools were used for advertising purposes in a manner it believed was compliant with all regulations. GoodRx chose to settle the alleged violations with the FTC for $1.5 million rather than fight them in court. The settlement agreement also requires GoodRx to refrain from sharing users’ health information with third parties for advertising purposes and to obtain consent before sharing data for non-advertising purposes.

Shortly after the FTC settlement was announced, a class action lawsuit was filed in the U.S. District Court of the Northern District of California against GoodRx that made similar allegations to the FTC – that personal information was disclosed to third parties without users’ knowledge or consent, when they had been informed on the website – between October 2017 and March 2019- that their personal information would not be disclosed to third parties. Specifically, the plaintiffs claimed that the website stated, “We never provide advertisers or any other third parties with any information that reveals a personal health condition of personal health information.”

The lawsuit asserted claims of common law invasion of privacy, intrusion upon seclusion, unjust enrichment, violations of the California Confidentiality of Medical Information Act (CMIA), aiding and abetting violations of CMIA, violations of the California Invasion of Privacy Act, violations of the California Consumers Legal Remedies Act, and violations of the California Business and Professional Code. Several other lawsuits were filed over the privacy violations, which were consolidated into a single action, – Jane Doe et al. v. GoodRx Holdings, Inc., et al. The consolidated lawsuit also asserts claims of negligence, negligence per se, and violations of New York’s General Business Law and the Illinois Consumer Fraud and Deceptive Business Practices Act.

Meta, Google, and Criteo were also named in the lawsuit as co-defendants, and all three companies are attempting to have the claims against them dismissed. District Court Judge Araceli Martinez-Olguin is due to issue a ruling on the plaintiffs’ motion to approve the $25 million settlement. Should the judge approve the settlement, the plaintiffs will be permitted to continue to pursue claims against the other co-defendants, as they are not part of the proposed settlement.

If approved, individuals whose privacy was violated will be permitted to file claims for a share of the settlement fund, after attorneys’ fees, service awards, and legal costs and expenses have been deducted. The plaintiffs’ attorneys are seeking one-third of the settlement amount – $8.33 million.

Update: The $25 million settlement agreement was rejected by the judge, as both sides failed to adequately demonstrate that the settlement was fair to consumers. There was a lack of claim-by-claim analysis showing the economic value and legal strength of each claim, unjustified financial discounts, missing evidence of confirmatory discovery, and overly broad liability releases.

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Hospital Ransomware Attacker Receives 70 Month Jail Term

Posted by Steve Alder

A Ukrainian affiliate of the Nefilim & Hive ransomware operations who attacked hospitals, government entities, and businesses over a three-year period has received a 70-month jail term. Ukrainian national Artem Aleksandrovych Stryzhak, 35, was arrested in Spain in June 2024 and was extradited to the United States on April 30, 2025, to face charges of alleged involvement in the Nefilim and Hive ransomware operations. Co-conspirator, Ukrainian national Volodymyr Tymoshchuk, was also indicted but remains at large. An $11 million reward has been offered by the U.S. Department of State for information that leads to his arrest.

Stryzhak was alleged to have joined the Nefilim ransomware operation as an affiliate in June 2021, and agreed to pay the ransomware operator 20% of any ransom payments he generated in exchange for access to the Nefilim group’s infrastructure and encryptor. Between June 2021 and October 2021, Stryzhak used Nefilim ransomware in multiple attacks on entities in the United States.

Stryzhak was also alleged to have been a member of the Hive ransomware operation between June 2021 and January 2023, and along with his co-conspirators, conducted attacks on hospitals, government entities, and businesses. According to the prosecutors, along with his co-conspirators, Stryzhak deployed Hive ransomware against seven victims, including law firms, a dentist’s office, and a healthcare provider during the COVID-19 pandemic.

Stryzhak pleaded guilty to conspiracy to commit fraud and related activity such as extortion in connection with international ransomware operations and faced up to 10 years in jail. At sentencing in federal court in Brooklyn on October 27, 2026, Stryzhak received a 70-month prison term. “Artem Stryzhak chose to deploy ransomware that extorted money from victims, leaving businesses and individuals facing devastating losses.  His actions serve as a strong reminder of the real-world damage cybercriminals can cause and underscore the FBI’s commitment to stopping these schemes and protecting the public,” stated FBI Assistant Director in Charge Barnacle.

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