litigation” including “doctrines such as foreseeability and proximate cause, directness of injury, certainty of damages, and privity of contract.”); Desiano v. Warner-Lambert Co., 326 F.3d 339, 346, 348 (2d Cir.2003) (Calabresi, J.) (noting that RICO’s “directness” requirement, which is more stringent than that imposed under most States’ proximate-cause jurisprudence, is a matter of statutory standing, but that RICO also incorporates traditional proximate cause requirements like foreseeability). On one side of the ledger, the Supreme Court’s decision in Holmes represents a classic statutory-standing case. The Court held that the Securities Investor Protection Corporation (SIPC) could not sue Robert Holmes, Jr. under RICO for losses it suffered as a r d 884, 890-91 (6th Cir.2000) (<HOLDING>); Firestone v. Galbreath, 976 F.2d 279, 285
holding that a plaintiff who did not have a direct contractual relationship with the defendant and who suffered injuries derivative of those realized by intermediate parties lacked standing to sue under rico holding that employers have standing to sue holding that a union lacked standing to sue for injuries passed on to it by intermediaries holding that plaintiffs lacked standing to sue holding that beneficiaries of an estate lacked standing under rico to sue for an injury derivative of the estates injury