In a Civil RICO case, the defendants argued that because the alleged pattern of racketeering activity consisted of acts of mail fraud, the plaintiffs must show that they relied on the fraudulent misrepresentations. “This they cannot do, because the alleged misrepresentations – attestations of compliance with the single simultaneous bidder rule – were made to the county, not plaintiffs. The county may well have relied on defendants? misrepresentations when it permitted them to participate in the auction, but plaintiffs, never having received the misrepresentations, could not have done so. If reliance is required, it must be by virtue of Section 1964(c), which provides the right of action. But it is difficult to derive a first-party reliance requirement from Section 1964(c), which states simply that ‘any person injured in his business or property by reason of a violation of Section 1962’ may sue for treble damages. The statute provides a right of action to ‘any person’ injured by the violation, suggesting a breadth of coverage not easily reconciled with an implicit requirement that the plaintiff show reliance in addition to injury in his business or property. Moreover, a person can be injured ‘by reason of’ a pattern of mail fraud even if he has not relied on any misrepresentations.” With respect to the requirement for proximate cause, the Court held, (among other things), that “there is no general common-law principle holding that a fraudulent misrepresentation can cause legal injury only to those who rely on it. The Restatement provision cited by petitioners certainly does not support that proposition. It provides only that the plaintiff’s loss must be a foreseeable result of someone’s reliance on the misrepresentation. It does not say that only those who rely on the misrepresentation can suffer a legally cognizable injury.” See Bridge v. Phoenix Bond & Indemnity Co.,128 S.Ct. 2131 (2008).