In a much-anticipated decision, the Illinois Appellate Court for the First District has ruled that two separate statutes of limitations apply to violations of the Illinois Biometric Information Privacy Act (“BIPA” or the “Act”). Specifically, the court in Tims v. Black Horse Carriers, Inc., 2021 IL App (1st) 200563 (Sept. 17, 2021), held that violations of Sections 15(c) and (d) of the Act must be brought within one year, while violations of Sections 15(a), (b) and (e) must be brought within five years.