Case file: Fragomen, Del Rey, Bernsen & Loewy, LLP
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
- May 4, 2026 to May 5, 2026
- Discovered
- May 5, 2026, as stated in the California letter
- State and federal records
- 4 filings, Oct 2, 2026 to Oct 6, 2026
- Residents counted
- 387 in 3 states (TX, VT, MA), latest filing per state
- Everyone affected
- 1,753, as reported to Texas AG on Oct 6, 2026
- Information exposed
- Social Security number, Driver's license / state ID, Passport number, Medical / health information
- Offered to those affected
- 24 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 3 states that set one, counted from discovery to each state's first record
- Prior incidents
- 1 earlier incident on record for this organization
The letter: "What Happened On May 5, 2026, Fragomen learned that an unauthorized third party gained remote access to a single user account, which we determined was part of a social engineering campaign."
Filings
| Agency | Record date | People | In total | Days to notice | Links |
|---|---|---|---|---|---|
| Texas Texas AG | Oct 6, 2026 | 379 | 1,753 | 154 days, statute 60 days, over | Record |
| Vermont Vermont AG | Oct 2, 2026 | 1 | 150 days, statute 45 days, over | Record | |
| Massachusetts Massachusetts OCABR | Oct 2, 2026 | 7 | 150 days, statute no fixed period | Record | |
| California California AG | Oct 2, 2026 | Not published | 150 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
- 154 days from discovery (May 5, 2026) to the Texas record (Oct 6, 2026). Statute: 60 days from determination that the breach occurred (Tex. Bus. & Com. Code § 521.053).
- 150 days from discovery (May 5, 2026) to the Vermont record (Oct 2, 2026). Statute: 45 days from discovery or notification of the breach (9 V.S.A. § 2435).
- 150 days from discovery (May 5, 2026) to the Massachusetts record (Oct 2, 2026). Statute: no fixed period from knowledge or reason to know of the breach (Mass. Gen. Laws ch. 93H, § 3).
- 150 days from discovery (May 5, 2026) to the California record (Oct 2, 2026). Statute: 30 days from discovery or notification of the breach (Cal. Civ. Code § 1798.82).
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.
- 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.
- 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).
Prior incidents by Fragomen, Del Rey, Bernsen & Loewy, LLP
| Records | Breach window | Filed with | People |
|---|---|---|---|
| Oct 23, 2020 | Jul 16, 2020 | California | n/a |
Filings more than six months apart are shown as separate incidents.
Sources and method
Records as published by Texas AG, Vermont AG, Massachusetts OCABR, California AG. 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.