The Eighth Circuit Court of Appeals last week reversed the district court’s approval of a settlement and settlement class in the consolidated consumer class action arising from Target Corporation’s 2013 security incident.  This decision provided a new perspective on a persistent dilemma in the evolving law of data breaches:  how to handle data breach victims whose data was compromised but not misused, and therefore they cannot show concrete monetary harm.  Here, that issue has at least temporarily derailed a multi-million settlement of the last major lawsuit arising out of Target’s high-profile incident.