Last year, the U.S. Supreme Court issued a decision in Spokeo Inc. v. Robins, holding that a plaintiff bears the burden of establishing Article III standing by alleging an injury in fact that is concrete, particularized, and actual or imminent. The Court stated that “Article III standing requires a concrete injury even in the context of a statutory violation,” and that a plaintiff cannot “allege a bare procedural violation, divorced from any concrete harm, and satisfy the injury in fact requirement of Article III.”

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