The ruling creates tension with First Circuit precedent. In Webb v. Injured Workers Pharmacy, the court expanded standing doctrine to accept lost time and mitigation efforts as concrete injuries sufficient to survive dismissal. Santos-Pagán does not overrule that line of cases but narrows its application. The court distinguished between injuries that flow from a breach's mere occurrence—which may survive under Webb—and injuries requiring proof of causation to the specific breach at issue. Here, the plaintiff's failure to plead facts establishing that connection proved dispositive.
Data breach defendants should note that motions to dismiss remain viable when plaintiffs cannot bridge the gap between breach and harm with specific allegations. While the First Circuit has grown more receptive to intangible injuries in cybersecurity litigation, Santos-Pagán reaffirms that standing doctrine still requires a direct link between the defendant's conduct and the plaintiff's injury. Practitioners defending these cases should scrutinize complaints for factual allegations of causation, not merely temporal proximity between breach and misuse.