The answer to this question has changed yet again. I’ve blogged on this topic several times in the past (see here, here and here), and described the question as a wriggling worm. Plaintiff Ciox Health, LLC has finally managed to catch that worm and share its bounty among those looking to charge third-party

On February 24, 2012, HHS posted number 400 on its ever-lengthening list of breaches of unsecured PHI affecting 500 or more individuals. Theft of laptops is a recurrent source of such breaches, and the 400th breach was such an incident affecting Triumph, LLC in North Carolina.
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