Case file: Apex Clean Energy Holdings, LLC
Every government filing on this incident, the dates as stated, and the days to notice against each state's statute. Built from the records on Nov 9, 2026, agency link on every row. Not legal advice.
The incident
- Breach window
- Mar 17, 2026 to Mar 23, 2026
- Discovered
- Mar 23, 2026, as stated in the Iowa letter
- State and federal records
- 4 filings, Nov 2, 2026 to Nov 3, 2026
- Residents counted
- 1,420 in 3 states (TX, VT, MA), latest filing per state
- Everyone affected
- 13,763, as reported to Texas AG on Nov 3, 2026
- Information exposed
- Social Security number, Driver's license / state ID, Passport number, Financial / bank account, Medical / health information, Health insurance, Email address
- Offered to those affected
- 12 months of credit or identity monitoring through Experian
- Third party named
- Yes, the letter attributes the incident to a vendor or service provider
- Days to notice
- Past the statutory period in all 2 states that set one, counted from discovery to each state's first record
The letter: "Apex first became aware of the incident on March 23, 2026 when Apex was alerted to unusual activity in its IT network."
Filings
| Agency | Record date | People | In total | Days to notice | Links |
|---|---|---|---|---|---|
| Texas Texas AG | Nov 3, 2026 | 1,387 | 13,763 | 225 days, statute 60 days, over | Record |
| Iowa Iowa AG | Nov 2, 2026 | Not published | 224 days, statute no fixed period | Letter Record | |
| Vermont Vermont AG | Nov 2, 2026 | 9 | 224 days, statute 45 days, over | Record | |
| Massachusetts Massachusetts OCABR | Nov 2, 2026 | 24 | 224 days, statute no fixed period | Record |
People is the count the filing gives, residents of the state unless marked total. Days to notice runs from the discovery date the letter states, or from the end of the breach window when no letter states one, to the date on the state's first record of the incident. "Over" marks a count past the days the state's statute allows for notice to residents. The statute's trigger is a question of fact, the days are arithmetic.
Notice timing, state by state
- 225 days from discovery (Mar 23, 2026) to the Texas record (Nov 3, 2026). Statute: 60 days from determination that the breach occurred (Tex. Bus. & Com. Code § 521.053).
- 224 days from discovery (Mar 23, 2026) to the Iowa record (Nov 2, 2026). Statute: no fixed period from discovery of the breach (Iowa Code § 715C.2).
- 224 days from discovery (Mar 23, 2026) to the Vermont record (Nov 2, 2026). Statute: 45 days from discovery or notification of the breach (9 V.S.A. § 2435).
- 224 days from discovery (Mar 23, 2026) to the Massachusetts record (Nov 2, 2026). Statute: no fixed period from knowledge or reason to know of the breach (Mass. Gen. Laws ch. 93H, § 3).
The statutes
- Texas: 60 days to notify residents from determination that the breach occurred, Tex. Bus. & Com. Code § 521.053. Attorney General within 30 days of determination when 250 or more Texas residents are affected.
- Iowa: no fixed period to notify residents from discovery of the breach, Iowa Code § 715C.2. Attorney General within 5 business days of the consumer notice when more than 500 Iowa residents are affected.
- Vermont: 45 days to notify residents from discovery or notification of the breach, 9 V.S.A. § 2435. Attorney General within 14 business days of discovery or of the consumer notice, whichever is sooner, every breach.
- Massachusetts: no fixed period to notify residents from knowledge or reason to know of the breach, Mass. Gen. Laws ch. 93H, § 3. Attorney General and OCABR as soon as practicable and without unreasonable delay, every breach.
Sources and method
Records as published by Texas AG, Iowa AG, Vermont AG, Massachusetts OCABR. Letter facts (discovery date, monitoring, third party) are read from the consumer letter the agency posted, 1 letter read for this incident, and quoted so you can check them. Texas and HHS publish no letters. First-seen times on each record page. Spot an error? Email support@breachtally.com with this page link.