Breach filing
Under investigationDr. Michael Bilikas and Associates d.b.a. 32 Pearls: 23,517 individuals, Jul 2025.
Dr. Michael Bilikas and Associates d.b.a. 32 Pearls reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 21 July 2025. The filing records the organisation as a healthcare provider in Washington and lists 23,517 individuals affected, which makes it the 39th largest of the 185 Washington filings on the register and the 215th largest of the 798 filings submitted nationally in 2025. Among the 17 Washington filings made in 2025 it ranks 5th.
Individuals affected
23,517
As reported to HHS
Modelled cost (IBM 2025)
$3.76M
Method shown, not disclosed
Rank in WA
39th
of 185 Washington filings
Rank in 2025
215th
of 798 filings nationally
Section F.1 / The filing
As posted by HHS OCR
Every value below is the portal's own field for this filing, plus its rank within the register.
- Covered entity type
- Healthcare Provider
- Individuals affected
- 23,517
- Breach submission date
- 21 July 2025
- Submission year
- 2025
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- No
- State
- Washington (WA)
- Portal status
- listed by HHS OCR under Cases Currently Under Investigation
- Rank in Washington by size
- 39th of 185
- Rank in 2025 nationally
- 215th of 798
- Washington median filing
- 3,950 individuals
- Register id (derived)
- WA-20250721-dr-michael-bilikas-and-associates-dba-32
Section F.2 / In context
Where this filing sits in Washington and in 2025
OCR classifies the incident as a hacking or IT incident, with the breached information held in a network server. Hacking/IT Incident is the type recorded on 117 of the 185 Washington filings (63%) and on 81% of all filings submitted in 2025. Network Server appears on 48% of Washington filings.
No business associate is recorded on the filing; 21% of Washington filings do involve one. At 23,517 individuals the breach is 6.0 times the Washington median filing of 3,950 and 5.9 times the national median of 4,000 across all 7,884 filings. It sits in the 10,000 to 99,999 band, which holds 1,938 filings.
As of 28 August 2026 the case is listed by HHS OCR under Cases Currently Under Investigation. OCR has not published a closing summary, so this page is limited to the fields on the filing itself; the archive entry that follows a closed investigation usually adds a short account of what was exposed and what the entity did afterwards.
Washington's breach notification statute (RCW 19.255.010) requires notice to affected residents no later than 30 days after discovery. Its attorney general threshold: more than 500 Washington residents. The HIPAA Breach Notification Rule ran alongside it: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery, which is the clock that put this filing on the portal.
Multiplying 23,517 individuals by IBM's $160 customer-PII cost per record (Cost of a Data Breach 2025, the figure the site's calculator uses) gives a modelled $3.76M; the 2026 edition's $192 gives $4.52M. Both are modelled estimates with the method shown, not costs disclosed by Dr. Michael Bilikas and Associates d.b.a. 32 Pearls. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.7 times the sector average.
Section F.5 / Modelled cost
23,517 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$3.76M
23,517 x $160
IBM 2026 customer PII, $192 per record
$4.52M
23,517 x $192
Method: individuals affected, as reported by Dr. Michael Bilikas and Associates d.b.a. 32 Pearls to HHS, multiplied by IBM's customer-PII cost per record (Cost of a Data Breach 2025 Figure 6 and the 2026 edition). No cost has been disclosed by the entity for this filing; the figure is a planning estimate, not a fact about the breach. IBM's per-record figures come from mid-volume breaches and IBM cautions against applying them to breaches involving millions of records; the site's per-record page explains where the multiplication holds and where it breaks down.
Context: IBM's average cost of a healthcare breach is $6.64M in the 2026 report ($7.42M in 2025); the global average across all sectors was $4.44M in 2025.
Cost per record: method and limits / Healthcare breach cost, IBM 2026
Section F.6 / Notification clock
Washington statute and the HIPAA rule
State notification statute
Washington: RCW 19.255.010
- Notice to individuals
- No later than 30 days after discovery
- Attorney general threshold
- More than 500 Washington residents (Within the same 30-day window)
- Private right of action
- Yes: Civil lawsuits under the Consumer Protection Act; actual damages plus up to $1,000 punitive for willful violations
- Penalty
- Consumers may recover damages, costs, and attorney fees; AG may seek penalties and injunctive relief
The HIPAA Breach Notification Rule runs alongside the state statute: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery.
Section F.7 / Peer filings
Washington filings closest in size
Neighbours by size rank among Washington filings in 2025, topped up from other years where 2025 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Behavioral Health ResourcesOpen | Healthcare Provider | 49,213 | 17 Jan 2025 | |||
| Klickitat Valley Health | Healthcare Provider | 26,339 | 14 Mar 2025 | |||
| Lake Washington VascularOpen | Healthcare Provider | 21,534 | 25 Feb 2025 | |||
| Northwest Denture Center, Inc.Open | Healthcare Provider | 19,419 | 25 Jul 2025 |
Index / Companion schedules
13 HHS breach register
→Hub: every filing, by state, year and entity.
04 Biggest breaches
→Mega-breaches with primary-source cost figures.
Industry / Healthcare
→IBM 2026: $6.64M average, 13 years at #1.
Regulation / HIPAA penalties
→OCR enforcement tiers and the 60-day rule.
11 50-state laws
→Deadline, AG threshold and penalties per state.
Cost / Per record
→Where the per-record model is reliable.
Provenance
Source: U.S. Department of Health and Human Services, Office for Civil Rights, Breach Portal (breaches affecting 500 or more individuals), retrieved 2026-08-28. Public domain. Individuals affected and dates as reported by the covered entity.
Portal: ocrportal.hhs.gov breach report. Statutory basis: HITECH Act section 13402(e)(4): the Secretary must post a list of breaches of unsecured protected health information affecting 500 or more individuals. Breaches affecting fewer than 500 individuals are reported to OCR annually and are not posted, so they are not on this register. Status wording follows the portal's two tabs ("Cases Currently Under Investigation" and "Archive") as of 28 August 2026; a filing moves to the archive when OCR closes the case. Modelled costs on this site are a method applied to the reported count, using IBM Cost of a Data Breach per-record figures, and are never a cost disclosed by the entity. This row: hhs-breach-under-investigation__2026-08-28.csv, export row 478.
Corrections: if you represent a listed entity and the portal row has been amended, email [email protected] with the portal entry and we will re-pull the export.