MEMORANDUM Date: [today's date] To: Miguel Rodriguez From: [student name] Re: Potential Liability for Data Breach Introduction [Provide an introduction in this section.] Liability for Negligence [Discuss potential liability for negligence under Colorado law in this section. The duty of care is the "obligation people ow each other not to cause any unreasonable harm or risk of harm." (Cheeseman, 2021, p. 99). Defenses [Discuss potential defenses in this section.] Conclusion [Give a brief conclusion in 1-2 sentences.] You are working at iHiker and learn that iHiker's computer system has been attacked by a computer virus from a cybercriminal. An employee of iHiker inadvertently opened an email with an attachment that appeared to come from the Colorado Secretary of State for business registration renewals. The names, addresses, phone numbers, credit card information, and other personal information of all iHiker customers have been compromised in the data breach. In your role working as a paralegal or legal assistant for iHiker, draft a memorandum to Miguel Rodriguez, the iHiker general counsel, analyzing potential civil liability for negligence under Colorado state law for the data breach. In the memorandum, specifically discuss the elements for negligence and the reasonable person standard. In addition, analyze any potential affirmative defenses that may apply.

MEMORANDUM Date: [today's date] To: Miguel Rodriguez From: [student name] Re: Potential Liability for Data Breach Introduction [Provide an introduction in this section.] Liability for Negligence [Discuss potential liability for negligence under Colorado law in this section. The duty of care is the "obligation people ow each other not to cause any unreasonable harm or risk of harm." (Cheeseman, 2021, p. 99). Defenses [Discuss potential defenses in this section.] Conclusion [Give a brief conclusion in 1-2 sentences.] You are working at iHiker and learn that iHiker's computer system has been attacked by a computer virus from a cybercriminal. An employee of iHiker inadvertently opened an email with an attachment that appeared to come from the Colorado Secretary of State for business registration renewals. The names, addresses, phone numbers, credit card information, and other personal information of all iHiker customers have been compromised in the data breach. In your role working as a paralegal or legal assistant for iHiker, draft a memorandum to Miguel Rodriguez, the iHiker general counsel, analyzing potential civil liability for negligence under Colorado state law for the data breach. In the memorandum, specifically discuss the elements for negligence and the reasonable person standard. In addition, analyze any potential affirmative defenses that may apply.