NOTES
1. FBI Cyber Division, Private Industry Notification, Health Care Systems and Medical Devices at Risk for Increased Cyber Intrusions for Financial Gain (April 8, 2014), http://www.illuminweb.com/wp-content/uploads/ill-mo-uploads/103/2418/health- systems-cyber-intrusions.pdf.
2. IBM and Ponemon Institute LLC, “2014 Cost of Data Breach Study: United States,” (May 2014).
3. See Advisory Council on Employee Welfare and Pension Benefit Plans, “Privacy and Security Issues Affecting Employee Benefit Plans” (November 2011) (the “2011 ERISA Advisory Council Report”) (setting forth recommendation that the U.S. Department of Labor “provide guidance concerning the protection of PII [personal
NOTES1. FBI Cyber Division, Private Industry Notification, Health Care Systems and Medical Devices at Risk for Increased Cyber Intrusions for Financial Gain (April 8, 2014), http://www.illuminweb.com/wp-content/uploads/ill-mo-uploads/103/2418/health- systems-cyber-intrusions.pdf.2. IBM and Ponemon Institute LLC, “2014 Cost of Data Breach Study: United States,” (May 2014).3. See Advisory Council on Employee Welfare and Pension Benefit Plans, “Privacy and Security Issues Affecting Employee Benefit Plans” (November 2011) (the “2011 ERISA Advisory Council Report”) (setting forth recommendation that the U.S. Department of Labor “provide guidance concerning the protection of PII [personal
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