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151640 Shareholder Rep. Services v. Airbus Americas 10/27/2016 In litigation growing out of the purchase of a corporation pursuant to a merger agreement, the circuit court correctly applied a damage cap on recovery by the purchaser for certain breaches by the sellers which all involved failure to use generally accepted accounting principles, as contemplated in the merger agreement, to accurately establish the financial condition of the acquired corporation and, accordingly, the appropriate adjustment to the consideration to be paid by the purchaser to the seller. While the parties' agreement provided for different caps in separate subsections, the plain language does not contemplate that more than one of these caps would be applicable where, as here, the damages of the party entitled to indemnity all result from the same conduct. Rather, the cap in each subsection carefully defines a set of breaches to which it will apply and the failure to adhere to generally accepted accounting principles was a breach of representations and warranties as contemplated in the section providing that damages were limited to the $5.8 million escrow fund. The circuit court erred in not limiting the defendants' liability to indemnify the purchaser to damages that escrow cap. The judgment is reversed and final judgment is entered.

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In June 2012 cryptographic hashes of approximately 6.4 million LinkedIn user passwords were stolen by Yevgeniy Nikulin and other hackers who then published the stolen hashes online.[173] This action is known as the 2012 LinkedIn hack. In response to the incident, LinkedIn asked its users to change their passwords. Security experts criticized LinkedIn for not salting their password file and for using a single iteration of SHA-1.[174] On May 31, 2013, LinkedIn added two-factor authentication, an important security enhancement for preventing hackers from gaining access to accounts.[175] In May 2016, 117 million LinkedIn usernames and passwords were offered for sale online for the equivalent of $2,200.[176] These account details are believed to be sourced from the original 2012 LinkedIn hack, in which the number of user IDs stolen had been underestimated. To handle the large volume of emails sent to its users every day with notifications for messages, profile views, important happenings in their network, and other things, LinkedIn uses the Momentum email platform from Message Systems.[177] 2ff7e9595c