Dinerstein v. Google, LLC

484 F. Supp. 3d 561 (2020)

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Dinerstein v. Google, LLC

United States District Court for the Northern District of Illinois
484 F. Supp. 3d 561 (2020)

SC

Facts

The University of Chicago Medical Center (the hospital) and Google, LLC (defendants) conducted research seeking to create predictive health models that could prevent patients from having to go back to the hospital. As part of the project, the hospital disclosed deidentified patient medical records to Google. These records included the dates on which services were provided to each patient. Matt Dinerstein (plaintiff) was a patient at the hospital during the research period. Dinerstein signed a generic admission agreement at the hospital, acknowledging that his medical information could be used for research purposes, but with the condition that the hospital comply with all state and federal laws. Dinerstein sued the hospital in contract, claiming a violation of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and thus the contract provision requiring the hospital to comply with federal law. Dinerstein alleged that Google’s widespread data mining of individuals could be used in combination with the deidentified patient information to reidentify patients involved in the research. The hospital and Google filed a motion to dismiss.

Rule of Law

Issue

Holding and Reasoning (Pallmeyer, J.)

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