Legal Seminar, Chicago, IL

 Experi used bank for payroll and other financial needs  Employee fell victim to “phishing email”  Provided fraudsters with bank login info  Fraudsters logged in and transferred $1.9 million from Experi’s accounts  Bank employed “secure token” technology  Requires entry of  User ID  Confidential 4-digit PIN  Six digit code from a “secure token” that randomly generates a new code every 60 seconds Experi-Metal v. Comerica Bank , (E.D. Mich. 2011)

Commercially Reasonable?

 Yes  Experi agreed to use of the secure token system to verify ID  The court also found that it was commercially reasonable as a matter of law