Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
Fourth Circuit: Rhonda L. Hutton v. National Board of Examiners
Where the fraudulent opening of lines of credit in plaintiffs' name can be plausibly traced to the deft's data breach, plaintiffs have suffered, at minimum, sufficient concrete and particular imminent harm to state a claim.