(1991) (court addressing ICFA unfairness claim must consider whether challenged practice “offends public policy as established by statutes, the common law or otherwise, or, in other words, whether it is at least within the penumbra of some established concept of unfairness”); ABC Bus. Forms, Inc. v. Pridamor, Inc., 2009 WL 4679477, at *1 (N.D.Ill. Dec. 1, 2009). Under this admittedly amorphous standard — which, having been adopted by the Illinois state courts, governs this court’s analysis under the Ene doctrine — a plaintiff may predicate an ICFA unfairness claim on violations of other statutes or regulations, like HAMP and IHPA, that themselves do not allow for private enforcement. See Gainer Bank, N.A. v. Jenkins, 284 Ill.App.3d 500, 219 Ill.Dec. 809, 672 N.E.2d 317, 318-19 (1996) (<HOLDING>); Ornelas v. Safeway Ins. Co., 1988 WL 102232,
holding that a private plaintiff may not being an action under the family educational rights and privacy act of 1974 because that statute does not create personal rights to enforce under 42 usc  1983 holding that the sensible and popular understanding of what a motor vehicle accident entails necessarily involves the motor vehicle being operated as a motor vehicle  holding that the statutory definition of motor vehicle is not controlling holding that plaintiff may predicate an icfa claim on defendants violation of the illinois motor vehicle retail installment sales act which itself does not allow for private rights of action holding that where statutory remedies exist private employees do not have a private cause of action for violation of state constitutional rights