>> This was pretty startling though, since Jan 2012 (18 months), 31 breaches have occurred related to this firm IN CA ALONE... American Express Travel Related Services Company, Inc and /or its Affiliates ("AXP")<<

I think this is a slight misinterpretation.  Data breach reporting is not based on location of the breach but on the number of CA residents potentially included in the breach.  The reporting standard is 500 or more residents.  

If you review the provided consumer notification, most of the breaches are of merchants who accept AX credit cards, including an engineering firm from CO, clothing retailer from PA and a brew pub in Concord, CA.   I believe that AX is reporting the breach because the merchants have no means to determine the residency of the card holders.  

Additional reports are associated with cardholder information recovered by law enforcement and reported to AX.  The breach in these cases is not AX or it would have had to been reported as such.  

What I find curious is the limited reporting by other credit card providers.

Bill Roach, CRM

Opinions are my own and not those of my employer or any other entity.

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