The expanding world of Internet commerce likely will generate a corresponding expansion of data breaches, with the result that e-commerce businesses increasingly will become the targets of consumer class action lawsuits. Breach litigation has become more prevalent as a result of a perceptible legal trend favoring consumers. Various federal appeals courts have allowed consumers to launch class action suits even though the alleged injury from a breach was small, or even nonexistent, in terms of a current and tangible financial loss.