Vargas v. Barclays Bank Delaware
Filing
49
ORDER granting 47 Letter Motion to Seal. Application GRANTED. The referenced letter may be filed with the proposed redactions. The unredacted version of the letter has been filed at Dkt. 42. (Signed by Judge Lorna G. Schofield on 1/27/2025) (mml)
Via ECF
Honorable Lorna G. Schofield
United States District Court
for the Southern District of New York
Thurgood Marshall United States Courthouse
40 Foley Square
New York, New York 10007
Re:
Application GRANTED. The referenced letter may
be filed with the proposed redactions. The
unredacted version of the letter has been filed at
Dkt. 42.
Dated: January 27, 2025
New York, New York
Vargas v. Barclays Bank Delaware
Case No. 24-cv-06549-LGS (S.D.N.Y.)
Dear Judge Schofield:
My firm, along with our co-counsel, Laukaitis Law LLC, represent the plaintiff and the
proposed class in the above-referenced action.
We submit this letter to move pursuant to Your Honor’s Individual Civil Rule I.D.3 to
seal certain sections of the letter and all the exhibits attached thereto that were previously
submitted by Defendant on January 15, 2025 (ECF No. 42).
Data breaches and identify theft are of a major concern today. This concern is
compounded where the allegations in an action are that a company entrusted with personally
identifiable information (“PII”) abused that trust and improperly disseminated PII to
unauthorized third-parties. And that is exactly what is alleged in this action that Defendant did
here. See Complaint (ECF No. 1) at p. 2, ¶ 1 (“This is a class action lawsuit against Barclays
Bank for: (i) its unlawful disclosure of Plaintiff’s personally identifiable information (“PII”)).
Multiplying this concern, is the fact that there are reports that Barclays was the target of a
data breach in April of 2024 where it allegedly failed to safeguard its customers information.
See e.g. Alleged Cyberattack by Hacker Duo Targets HSBC and Barclays; Banks Deny Breach,
by Ashish Khaitan, May 10, 2024 available at Barclays And HSBC Bank Data Breach Claimed
By Hacker Duo (“the breach at Barclays reportedly occurred in April 2024, involving a
security incident through a third-party contractor, ultimately leading to the leak of sensitive
data.”). Moreover, this is not the first time that Defendant has reportedly failed to safeguard its
customers confidential, personal financial information. See e.g. Barclays Bank Leaks Thousands
of Customer Records, ComputerWeekly.com; by Warwick Ashford, February 10, 2014 available
at Barclays bank leaks thousands of customer records | Computer Weekly.
The information we seek to have filed under seal is the type of information that hackers
and other criminals seek to steal in data breaches in order commit identity theft. See e.g., In re
Geico Customer Data Breach Litig., case no. 2023 WL 4778646 (E.D.N.Y. July 21, 2023)(data
breach involving theft of customer’s driver’s license numbers); Dugas v. Starwood Hotels &
Resorts Worldwide, Inc., 2016 WL 6523428 (S.D. Cal. 2016)(data breach involving theft of first
and last names and credit cards numbers). Accordingly, we respectfully request that the
information be filed under seal.
Case 1:24-cv-06549-LGS
Document 47
Filed 01/24/25
Page 2 of 2
Honorable Lorna G. Schofield
Vargas v. Barclays Bank
Motion to Seal ECF No. 42
Page 2 of 2
Respectfully submitted,
Michael R. Reese
Appendix Pursuant to Individual Civil Rule I.D.3
Defendant and all counsel representing Defendant in this matter who are subject to the
Confidentiality Order (ECF No. 37) should have access to the letter previously filed under seal
(ECF No. 42).
Case 1:24-cv-06549-LGS
Document 47-1
Filed 01/24/25
Page 1 of 3
THE FOLLOWING IS A PARTIALLY REDACTED VERSION OF ECF NO. 42
PREVIOUSLY FILED ON JANUARY 15, 2025
REDACTED
Case 1:24-cv-06549-LGS
Document 47-1
Filed 01/24/25
Page 2 of 3
REMAING SECTION OF PARAGRAPH REDACTED
REDACTED
Case 1:24-cv-06549-LGS
Document 47-1
Filed 01/24/25
Page 3 of 3
Case 1:24-cv-06549-LGS
Document 47-2
Filed 01/24/25
Page 1 of 4
THE FOLLOWING IS A PARTIAL REDACTION OF ECF No. 42-1
REDACTED
Case 1:24-cv-06549-LGS
Document 47-2
Filed 01/24/25
Page 2 of 4
Case 1:24-cv-06549-LGS
Document 47-2
Filed 01/24/25
Page 3 of 4
Case 1:24-cv-06549-LGS
Document 47-2
Filed 01/24/25
REDACTED
Page 4 of 4
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?