consumer fraud statutes of Delaware, Nebraska or North Dakota which suggest any different test would be applied to interpret the proximate cause element under the consumer fraud statutes in those respective states. Duphily v. Delaware Elec. Cooperative Inc., 662 A.2d 821, 828-829 (Del.1995); Stiver v. Allsup, Inc., 255 Neb. 687, 587 N.W.2d 77, 82 (1998), Jones v. Ahlberg, 489 N.W.2d 576, 582 (N.D.1992). On the other hand, North Carolina applies only the “substantial factor” test in defining the elements of proximate cause. American Rockwool, Inc. v. Owens Coming Fiberglas, 640 F.Supp. 1411, 1444 (E.D.N.C.1986). Michigan combines a “but for” test of proximate cause with a “socially and economically desirable” test. Adas v. Ames Color-File, 160 Mich.App. 297, 407 N.W.2d 640, 642 (1987) (<HOLDING>). Differences exist among the several states
holding that proximate cause requires two factors 1 cause in fact but for causation and 2 legal cause  the nexus between the wrongful acts and the injury sustained must be of such a nature that it is socially and economically desirable to hold the wrongdoer liable holding that use of tangible property must be proximate cause of injury and that property does not cause injury if it does no more than furnish the condition that makes the injury possible holding that a physicians negligence need only be a proximate cause not the proximate cause of plaintiffs injury holding that whether the negligent acts of parties combined to become the proximate cause of the injury was a question for the jury holding that negligence must be the proximate cause of injury