"For the second time this year, the U.S. District Court for the Northern District of California has ruled that state law claims arising from Anthem's February data breach are preempted by [ERISA] ... The participants sought to enforce their rights under the ERISA plan through their breach-of-contract and unjust-enrichment claims. Since these claims were premised on the insurance contract between the participants and Anthem they could have brought their actions under [ERISA] Section 502(a), the court concluded. In addition, Anthem didn't have an independent legal duty to protect participants' privacy pursuant to state law, the court said." [In re Anthem, Inc. Data Breach Litig., No. 15-CV-04739-LHK (N.D. Cal. Nov. 24, 2015)]