Law360, New York (March 14, 2012, 2:10 PM EDT) -- As security breaches become more prevelant, class actions arising out of these data security breaches are now on the rise. In 2010, the Federal Trade Commission reported that there were over 725,000 cases of fraud. This is up more than 12.7 percent from 2008. Despite the increased awareness of the necessity of online security, the majority of data security breaches occur through digital contact. Large data security breaches impose significant costs on corporations to rectify the breach. For example, Sony Corp. has already had to pay an estimated $171 million to clean up the breach of the PlayStation network. See Larry Dignan, Sony's Data Breach Costs Likely to Scream Higher, ZdNet, May 24, 2011....