In re : Snowflake, Inc. (Feb. 5, 2026)

Case details
Full caption
In re: Snowflake, Inc., Data Security Breach Litigation
Country
United States
Jurisdiction
Federal
Decided
Feb. 5, 2026
IN RE: SNOWFLAKE, INC., DATA SECURITY BREACH LITIGATION, Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 318355Only the Westlaw citation is currently available.United States District Court, E.D. California.IN RE: SNOWFLAKE, INC., DATASECURITY BREACH LITIGATIONMDL No. 3126|Filed 02/05/2026Editor's Note: This decision contains discussion of citationreferences that are incorrect or do not actually exist. Theseinvalid citations appeared in the original court opinion andhave been preserved as written since they are part of theofficial record. Any links to these invalid citations have beenremoved.TRANSFER ORDERUNITED STATES JUDICIAL PANELon MULTIDISTRICT LITIGATION*1 Before the Panel:* Pro se plaintiff in the action listed onSchedule A (Jones II) moves under Panel Rule 7.1 to vacatethe order conditionally transferring the action to the Districtof Montana for inclusion in MDL No. 3126. Defendant AT&TInc. opposes the motion and supports transfer.After considering the parties’ arguments, we find that theaction involves common questions of fact with the actionstransferred to MDL No. 3126, and that transfer under 28U.S.C. § 1407 will serve the convenience of the partiesand witnesses and promote the just and efficient conductof the litigation. The actions in MDL No. 3126 involvecommon factual questions concerning a cluster of databreaches that occurred on the Snowflake cloud platform fromapproximately April through June 2024, when a threat actorallegedly exfiltrated the personal information of over 500million consumers and employees, including AT&T cellularcustomers. See In re AT&T Inc. Cellular Customer Data Sec.Breach Litig., 753 F. Supp. 3d 1368, 1371 (J.P.M.L. 2024). Incentralizing the actions, we observed that the breach of AT&Tdata on the Snowflake cloud allegedly involves metadata forcalls and texts made by AT&T cellular customers and certainothers using the AT&T network from May 1, 2022, to October31, 2022, and, for some customers, records from January2, 2023. Id. at 1372-73 n.6. The Jones II action involvesoverlapping factual issues concerning the breach of AT&Tdata on the Snowflake platform – in particular, the breach oftext messaging and call data from May 2022 to October 2022and in January 2023. Notably, plaintiff filed a substantiallyidentical action against AT&T in late 2024 that we previouslytransferred to the MDL (Jones I).1 Transfer will facilitate theefficient conduct of overlapping pretrial proceedings in JonesI and Jones II, as well as the other actions in the MDL, andavoid the risk of inconsistent rulings.In opposition to transfer, plaintiff principally argues that (1)Jones II concerns breaches related exclusively to AT&T, incontrast to Snowflake, thus eliminating any common factualquestions with the MDL; (2) the damages in Jones II areplaintiff-specific; (3) he opted out of the class settlement inthe MDL; and (4) transfer would unfairly delay the resolutionof his claims and cause inefficiency. These arguments areunpersuasive.First, plaintiff's assertion that the MDL does not include thebreach of AT&T data alleged in Jones II is wrong. Our initialtransfer order clearly states that the MDL includes actionsagainst AT&T and specifies that the AT&T incident at issuein the Snowflake MDL is the one announced by AT&T in July2024 “involv[ing] metadata for calls and texts made by AT&Tcellular customers ... from May 1, 2022 to October 31, 2022,and, for some customers, records from January 2, 2023.” SeeIn re AT&T Inc. Cellular Customer Data Sec. Breach Litig.,753 F. Supp. 3d at 1373-73 & n.6. These specific data sets areat issue in Jones II.*2 There is no basis for excluding Jones II from the MDLbased on the complaint's exclusive focus on AT&T as thealleged wrongdoer, the omission of allegations concerningSnowflake, and the inclusion of additional alleged databreaches spanning 2021-2024. Section 1407 does not requirea complete identity of common factual issues or parties when,as here, the actions arise from a common factual core. See Inre Valsartan Prods. Liab. Litig., 433 F. Supp. 3d 1349, 1352(J.P.M.L. 2019). The asserted differences raised by Jones IIalso are undercut by the fact that, by plaintiff's own account,Jones II raises the same factual issues as the Jones I actionpending in the MDL.Second, plaintiff's individualized injuries do not weighagainst transfer. The existence of individualized injuries doesnot negate the efficiencies gained by transfer. See, e.g., In re
IN RE: SNOWFLAKE, INC., DATA SECURITY BREACH LITIGATION, Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.2Fluoroquinolone Prods. Liab. Litig., 122 F. Supp. 3d 1378,1379 (J.P.M.L. 2015). Further, many of plaintiff's allegedinjuries – for example, emotional distress from the breach andthe increased risk of fraud – are largely the same types ofinjuries alleged in the MDL. Indeed, they are the same injuriesalleged in Jones I. Additionally, like the MDL plaintiffs,plaintiff Jones seeks punitive damages against AT&T.Third, plaintiff's decision to opt out of the class settlementdoes not affect transfer. We routinely transfer opt-out actionsto MDLs with class settlements because of the efficienciesto be gained from the transferee court's management ofoverlapping actions and expertise in the issues. See, e.g., Inre Payment Card Interchange Fee and Merchant DiscountAntitrust Litig., MDL No. 1720, Transfer Order at 2 (J.P.M.L.Oct. 16, 2013).Fourth, transfer is warranted despite the alleged delay andinconvenience from transfer. Plaintiff's grievances about thetemporary stay of proceedings in the MDL and the allegedlack of progress in Jones I are not to the contrary. All ofthese grievances are essentially disagreements with how tostructure the proceedings in the MDL. Dissatisfaction withthe course of pretrial proceedings in an MDL is not a factor indeciding whether to transfer otherwise factually-related cases.See id. at 2 & n.3 (transferring opt-out plaintiffs’ actions overtheir objections concerning how the MDL was managed).Moreover, we look to “the overall convenience of the partiesand witnesses in the litigation as a whole, not just those ofa single plaintiff or defendant in isolation.” See In re WatsonFentanyl Patch Prods. Liab. Litig., 883 F. Supp. 2d 1350,1351-52 (J.P.M.L. 2012).Finally, we must raise an additional issue, given ourserious concerns about the integrity of the record in thismatter. Plaintiff's briefs misrepresent the holdings andfabricate quotations with respect to at least seven Paneldecisions.2 Additionally, two of the citations in plaintiffs’briefs appear to be fabricated.3 The nature and number ofthe misrepresentations strongly suggest that plaintiff usedgenerative artificial intelligence to draft his briefs withoutchecking the accuracy of the information produced,4 thoughit also is possible he used some other unreliable source.Regardless, plaintiff improperly submitted briefs with falselegal representations. We admonish plaintiff for fabricatingand misrepresenting legal authorities in his briefing. This isan abuse of the judicial process, and one which we do not takelightly.*3 Although pro se filings are held to less stringentstandards than formal pleadings drafted by lawyers, alllitigants (whether represented by counsel or not) are subjectto an affirmative duty to conduct a reasonable inquiry into thesubstance of a filing before they present it to a court. Thisduty includes ensuring that citations and quotations are, infact, real, as we recognized in a similar pro se matter last year.See In re Snowflake, Inc., Data Sec. Breach Litig., MDL No.3126, ___ F. Supp. 3d ___, 2025 WL 4007421, at *2 (J.P.M.L.Aug. 7, 2025). Any further non-compliant submissions fromplaintiff may be stricken or result in additional appropriatecorrective action.IT IS THEREFORE ORDERED that the action listed onSchedule A is transferred to the District of Montana and, withthe consent of that court, assigned to the Honorable BrianMorris for coordinated or consolidated pretrial proceedings.PANEL ON MULTIDISTRICT LITIGATION[illegible text]Nathaniel M. GortonActing ChairRoger T. BenitezMadeline Cox ArleoDale A. KimballIN RE: SNOWFLAKE, INC., DATA SECURITYBREACH LITIGATIONSCHEDULE AEastern District of CaliforniaJONES v. AT&T INC., C.A. No. 2:25–02952MDL No. 3126All CitationsSlip Copy, 2026 WL 318355
IN RE: SNOWFLAKE, INC., DATA SECURITY BREACH LITIGATION, Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.3Footnotes*Judge Karen K. Caldwell, Judge Matthew F. Kennelly, and Judge David C. Norton did not participate in thedecision of this matter.1See Jones v. AT&T, Inc., No. 24-3368 (E.D. Cal. filed Dec. 2, 2024). The conditional transfer order transferringJones I to the District of Montana became effective on January 2, 2025. See In re Snowflake, Inc., Data Sec.Breach Litig., MDL No. 3126, ECF No. 280 (J.P.M.L. Jan. 2, 2025). Jones I was docketed in the transfereecourt as Case No. 25-00001.2The misrepresentations and fabricated quotations, which appear in plaintiff's motion to vacate and reply brief(ECF Nos. 363 and 373), purport to be from the following: In re Xarelto Prods. Liab. Litig., MDL 2591, JPMLOrder (Apr. 2016); In re Plumbing Fixtures Litig., 298 F. Supp. 484, 495 (J.P.M.L. 1968); In re IBM PeripheralEDP Devices, 407 F. Supp. 254, 256 (J.P.M.L. 1976); In re Pharmacy Benefit Managers Antitrust Litig., 341F. Supp. 2d 1356 (J.P.M.L. 2004); In re Phenylpropanolamine (PPA) Prods. Liab. Litig., 460 F.3d 1217,1231 (9th Cir. 2006); In re Scotch Whiskey Antitrust Litig., 299 F. Supp. 543, 544 (J.P.M.L. 1969); and In reBridgestone/Firestone Tires Prods. Liab. Litig., 128 F. Supp. 2d 1196, 1198 (S.D. Ind. 2001).3For the fabricated citations, see Pl.’s Mot. to Vacate at 8 (J.P.M.L. Oct. 28, 2025) (citing “In re Xarelto Prods.Liab. Litig., MDL 2591, JPML Order (Apr. 2016)”) and Pl.’s Reply, at 2,10 (J.P.M.L. Dec. 3, 2025) (citing “Inre Pharmacy Benefit Managers Antitrust Litig., 341 F. Supp. 2d 1356 (J.P.M.L. 2004)”).4See Reilly v. Connecticut Interlocal Risk Mgmt. Agency, No. 25-630, 2025 WL 1726366, at *2-3 (D. Conn.June 20, 2025) (“Artificial intelligence is known to result in ... fictional or hallucinatory citations .... [B]ecauseartificial intelligence synthesizes many sources with varying degrees of trustworthiness, reliance on artificialintelligence without independent verification renders litigants unable to represent to the Court that theinformation in their filings is truthful.”) (internal quotation marks and citation omitted).End of Document© 2026 Thomson Reuters. No claim to original U.S. Government Works.
ProvenanceKnow exactly where this document came from.Members see the sourcing behind every authority on DocPost — so you can check the record yourself and cite with confidence.Request access