================================================================ CFP SUBMISSION - Death by a Thousand Paper Cuts Case 25CIV60102KCX | King County District Court | Judgment for plaintiff Conference-agnostic draft (BSidesPDX 2026 primary; reusable for BSides Seattle) ================================================================ --- TITLE ------------------------------------------------------- Death by a Thousand Paper Cuts: Making Corporate Data Negligence Expensive, One Small Claims Case at a Time --- DURATION ---------------------------------------------------- 20 minutes (BSidesPDX default). The content is a tight, replicable playbook and fits the slot without padding. Not requesting 40. --- ABSTRACT (public-facing) ------------------------------------ A Minneapolis data broker lost my name, SSN, and date of birth in the MOVEit/Cl0p breach, notified me 42 days late in violation of Washington's 30-day law, then refused my $1,050 invoice for the remediation time their negligence cost me. I filed in small claims, beat their corporate jurisdiction motion, and the judge ruled that a security professional's time assessing a breach is compensable at professional rates. They paid. This talk is the replicable playbook: a $50 filing fee, a few hours of prep, no lawyer. Class actions pay lawyers. Small claims pays you. --- DESCRIPTION (reviewer-facing) ------------------------------- In 2023 Pension Benefit Information, LLC lost my PII in the MOVEit/Cl0p breach. Notification came 42 days after their own discovery, past Washington's 30-day statutory deadline. I documented my remediation time, invoiced PBI $1,050, and was refused. I filed small claims in King County District Court. PBI showed up with corporate counsel and a motion to dismiss for lack of jurisdiction. On March 16, 2026 the court denied the motion and entered judgment for me. The talk walks the room through how and why it worked, then hands them the template to do it themselves. Judge Finkle's findings are the spine: - Washington had jurisdiction over an out-of-state broker because 18,856 WA residents were affected and had no practical recourse elsewhere - PBI filed breach notices with the WA AG. - I could opt out of the pending class action and pursue an individual remedy; the class action did not bar the claim. - A single vulnerability with no defense-in-depth is negligence. - One hour of expert evaluation is compensable at professional rates. Routine tasks any victim could perform are not - the judge draws that line explicitly, and your documentation has to respect it. From there: the 14-step template - finding the correct legal entity vs the name on the letter, archiving the broker's web presence before litigation makes it vanish, logging expert vs routine time, serving the registered agent (you cannot serve them yourself), surviving the jurisdiction motion, mediation, and closing the record with a Satisfaction of Judgment. Who it's for: anyone in the room. Most PNW infosec folks were in this exact breach or one like it. The barrier to acting has been "I'd need a lawyer." You don't. The barrier is now documentation discipline, which is a skill this audience already has. Attendees leave with: the entity-identification workflow, the time-log and rate-basis structure that survived trial, the service-of-process gotchas that get cases dismissed, and a complete step list they can run. --- CATEGORY FLAGS (your call - my recommendation) -------------- [ ] Beginner Speaker -> NO. 40 yrs, KSC + 18 yrs MS security. [X] 101 track -> YES, recommend. Broadly accessible and empowering regardless of seniority; the point is "anyone can do this." [ ] OTR -> NO. Public record; recording is fine and helps the playbook spread. [ ] 2nd Stage -> Optional. Fine with a smaller room. --- NOTES TO REVIEWERS ------------------------------------------ - I am the plaintiff and the speaker. Every document is either public court record (25CIV60102KCX) or my own work. Supporting docs are linked from the talk page. - The judgment is final and closed. PBI paid, I cashed the check, and a Satisfaction of Judgment is filed. Because the award fell below Washington's $1,000 small-claims appeal threshold, PBI had no right of appeal - the win is settled, not pending. - IANAL. This is a documented legal-strategy framework, not legal advice. Procedures and limits vary by jurisdiction; I say so on stage and in the materials. - AI usage disclosure (per your guideline): the substance, the case, and the template are mine - I lived it and wrote it. I used an AI assistant only to condense and reorganize this submission for your 20-minute format and to retune copy from a prior version. No inflation, no fabricated content. I have proofread and I own it. --- SPEAKER ----------------------------------------------------- Ken Hollis - 40 years in technology: Kennedy Space Center (Shuttle launch operations), enterprise networking, SCADA/ICS, and 18 years at Microsoft including 11 in security engineering (Cyber Defense Operations Center, critical-infrastructure and ICS security). Retired, in the PNW. Not a lawyer. Won anyway. --- SUPPORTING DOCUMENTS (linked from talk page) ---------------- PaperCuts_25CIV60102KCX_Judgment_After_Trial.pdf PaperCuts_25CIV60102KCX_Argument.pdf PaperCuts_25CIV60102KCX_Evidence.pdf PaperCuts_25CIV60102KCX_Small_Claims_Defendants_Packet.pdf PaperCuts_25CIV60102KCX_Small_Claims_Plaintiffs_Packet.pdf PaperCuts_CFP_Outline_Hollis.txt