Case file: flexPATH Strategies, 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
- Dec 7, 2018
- Discovered
- Dec 14, 2018, as stated in the California letter
- State and federal records
- 3 filings, Mar 15, 2019 to Apr 17, 2019
- Residents counted
- No state publishes a resident count for this incident
- Everyone affected
- 60,862, as reported to Oregon DOJ on Mar 15, 2019
- Information exposed
- Not stated in the listings
- Offered to those affected
- credit or identity monitoring through Experian (term not stated in the letter we read)
- 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: "On December 14, 2018, our ongoing investigation into a phishing email incident at flexPATH determined that an unauthorized person had obtained access to an email account belonging to a flexPATH employee."
Filings
| Agency | Record date | People | In total | Days to notice | Links |
|---|---|---|---|---|---|
| California California AG | Apr 17, 2019 | Not published | Later filing, first record Mar 15, 2019 | Letter Record | |
| Oregon Oregon DOJ | Mar 15, 2019 | 60,862 (total) | 91 days, statute 45 days, over | Record | |
| California California AG | Mar 15, 2019 | Not published | 91 days, statute 30 days, over | Letter 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
- 91 days from discovery (Dec 14, 2018) to the Oregon record (Mar 15, 2019). Statute: 45 days from discovery or notification of the breach (ORS 646A.604).
- 91 days from discovery (Dec 14, 2018) to the California record (Mar 15, 2019). Statute: 30 days from discovery or notification of the breach (Cal. Civ. Code § 1798.82).
The statutes
- California: 30 days to notify residents from discovery or notification of the breach, Cal. Civ. Code § 1798.82. Sample notice to the Attorney General when more than 500 Californians are notified, within 15 days of the consumer notice (effective 2026).
- Oregon: 45 days to notify residents from discovery or notification of the breach, ORS 646A.604. Attorney General when more than 250 Oregon residents are affected, with the consumer notice.
Sources and method
Records as published by California AG, Oregon DOJ. Letter facts (discovery date, monitoring, third party) are read from the consumer letter the agency posted, 2 letters 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.