as securities fraud.” H.R. Rep. No. 104-396, at 47 (1995) (Conf. Rep.). “[C]ourts have applied the RICO bar in § 1964(c) broadly, regardless of whether the plaintiff explicitly relied upon securities fraud as a predicate act or even had standing to pursue a securities fraud claim.” Licht v. Watson, 567 Fed.Appx. 689, 693 (11th Cir. 2014) (citing Bald Eagle Area Sch. Dist. v. Keystone Fin., Inc., 189 F.3d 321, 330 (3d Cir. 1999)). “[A] plaintiff cannot avoid the RICO Amendment’s bar by pleading mail fraud, wire fraud and bank fraud as predicate offenses in a civil RICO action if the conduct giving rise to those predicate offenses amounts to securities fraud.” Bald Eagle Area Sch. Dist., 189 F.3d at 330. See also MLSMK Inv. Co. v. JP Morgan Chase & Co., 651 F.3d 268, 277 (2d Cir. 2011) (<HOLDING>); Howard v. Am. Online, Inc., 208 F.3d 741, 749
holding that the rico bar applies even where the plaintiff does not have standing to bring a securities fraud action holding that a plaintiff cannot avoid the securities fraud exception by pleading mail fraud or wire fraud if the conduct giving rise to those offenses also amounts to securities fraud holding that the pslra bar applies even where a plaintiff cannot itself pursue a securities fraud action against the defendant holding that securities fraud claims cannot rest on speculation and conclusory allegations holding that an action against a tribal enterprise is an action against the tribe itself