Data breaches that expose consumer information to hackers are an increasingly and, distressingly, familiar problem, with a near-constant stream of headlines discussing the latest data breach suffered by a major company. Yet, while breaches generate a great deal of media attention and consumer concern, plaintiffs have struggled to convert these incidents into successful class action lawsuits. Few courts have certified damages classes of breach victims, in large part due to the problem of defining exactly how consumers suffered a common (as opposed to individualized) harm by exposure of their personal data.