Case file: Transform SR Holding Management 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
- Jun 3, 2021 to Jun 24, 2021
- Discovered
- Jun 24, 2021, as stated in the California letter
- State and federal records
- 3 filings, Jul 26, 2021
- Residents counted
- No state publishes a resident count for this incident
- Everyone affected
- 180,000, as reported to Oregon DOJ on Jul 26, 2021
- Information exposed
- Social Security number, Financial / bank account, Health insurance
- Offered to those affected
- credit or identity monitoring through Experian (term not stated in the letter we read)
- Third party named
- No
- Days to notice
- Past the statutory period in 1 of the 3 states that set one, counted from discovery to each state's first record
The letter: "On June 24, 2021, we determined that certain files on Transformco’s computer network may have been accessed by the unauthorized party."
Filings
| Agency | Record date | People | In total | Days to notice | Links |
|---|---|---|---|---|---|
| Oregon Oregon DOJ | Jul 26, 2021 | 180,000 (total) | 32 days, statute 45 days | Record | |
| California California AG | Jul 26, 2021 | Not published | 32 days, statute 30 days, over | Letter Record | |
| Delaware Delaware DOJ | Jul 26, 2021 | Not published | 32 days, statute 60 days | 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
- 32 days from discovery (Jun 24, 2021) to the Oregon record (Jul 26, 2021). Statute: 45 days from discovery or notification of the breach (ORS 646A.604).
- 32 days from discovery (Jun 24, 2021) to the California record (Jul 26, 2021). Statute: 30 days from discovery or notification of the breach (Cal. Civ. Code § 1798.82).
- 32 days from discovery (Jun 24, 2021) to the Delaware record (Jul 26, 2021). Statute: 60 days from determination of the breach (6 Del. C. § 12B-102).
The statutes
- 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.
- 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).
- Delaware: 60 days to notify residents from determination of the breach, 6 Del. C. § 12B-102. Attorney General when more than 500 Delaware residents are affected, no later than the resident notice.
Sources and method
Records as published by Oregon DOJ, California AG, Delaware 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.