id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ihlr-27442	Perkins, Nicole B.	Spreading a Digital Disease: The Circuit Split on Data Breaches and Its Effects on the Health Sector	2023	25	.pdf	application/pdf	10932	568	57	Unlike financial identity theft victims, medical identity theft victims have very few private remedies available, which is problematic in how valuable medical information is for criminals.13 Personal Health Information (“PHI”) is more valuable on the black market than credit card credentials or regular Personally Identifiable Information (“PII”).14 Therefore, there is a higher incentive for cyber criminals to target medical databases.15 Those breaches have resulted in the loss, theft, exposure, or impermissible disclosure of 268,189,693 healthcare records,16 which equates to more than 81.72 percent of the population of the United States.17 In 2018, healthcare data breaches of 500 or more records were being reported at a rate of around one per day.18 In December 2020, that rate had doubled. TransUnion further indicates that a statutory violation, like the one found in Horizon, will not be enough for future victims of healthcare data breaches to find legal recourse.	cache/ihlr-27442.pdf	txt/ihlr-27442.txt