Third Circuit Shreds Plaintiff's Credit Card Receipt Case On Standing Grounds

The Third Circuit recently held that procedural violations of the Fair and Accurate Credit Transactions Act ("FACTA"), absent any showing of concrete harm, do not meet Article III standing requirements.  Kamal v. J. Crew Group, 2019 WL 1087350 (3rd Cir. 2019).

Plaintiff Ahmed Kamal commenced a suit against J. Crew Group after making purchases at various J. Crew retail stores.  Kamal's receipts allegedly violated FACTA because they contained the first six and last four digits of his credit card number as well as the name of his card issuer.  Although Kamal conceded that neither his identity nor his credit card number were ever stolen, he maintained that the printing of FACTA-prohibited information and the resulting increased likelihood of identity theft constituted the concrete harm necessary for Article III standing.  Judge William J. Martini of the United States District Court for the District of New Jersey disagreed, and granted J. Crew's motions to dismiss for