and the word “participate” to require some part in that direction, the meaning of § 1962(c) comes into focus.... [S]ome part in directing the enterprise’s affairs is required. The “operation or management” test expresses this requirement in a formulation that is easy to apply. Reves, — U.S. at —, —, 113 S.Ct. at 1163, 1169-70 (dismissing civil RICO count under § 1962(c) where accounting firm failed to alert shareholders and directors of potential worthlessness of Co-op gasohol plant). “Relying on a dictionary definition of “conduct” as “mean[ing] to lead, run, manage, or direct,” the court explicitly rejected the view that ‘almost any involvement in the affairs of an enterprise’ [would state a claim].” Amalgamated, Bank of New York v. Marsh, 823 F.Supp. 209, 219, (S.D.N.Y.1993) (<HOLDING>). Reves did not foreclose the possibility of
holding a guideline amendment substantive primarily because it contradicted existing circuit precedent holding that an intervening supreme court case can overturn circuit precedent holding reves standard narrower than existing second circuit precedent holding that congress intended to adopt a standard more stringent than the prepslra second circuit standard holding the pslra codified the prior standard set up by the second circuit