The legal fallout from the massive Target data breach that compromised the credit card and personal information of up to 110 million customers has been significant. Target was named in over 50 class action lawsuits, filed both by consumers whose information was compromised and financial institutions that issued at least 40 million compromised cards. In a guest article, Debevoise & Plimpton attorneys Jeremy Feigelson, David A. O’Neil, Jim Pastore and Megan K. Bannigan detail the two settlements Target has announced, and discuss how those settlements provide insight on the form future large-scale data breach settlements could take.