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Yes, likely so.
HIPAA forbids you describing anything about a patient, their ailment, their treatment, etc. without a release. The law doesn't specifically state that to be in violation the information must also contain their name.
You would have to have a statement that did more than just state no one's real name was used. We aren't allowed to give you specific language or draft documents for you, so you'd have to get a local lawyer or a contract lawyer to draft the actual language but essentially you would have to state that you didn't take anything from real patients and you would want the statement to track the language of HIPAA.
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