may have had on competition or consumers.”). Much like the FMIA, § 190.65 does not require the government to prove as an element of the offense that either competition or consumers were impacted. Section 190.65 requires only an intent to defraud multiple individuals and a fraudulent taking from at least one individual. It does not require that those individuals be “consumers” or that competition be impacted in any way. This reading of § 190.65 is consistent with the interpretation of courts who have determined that similarly worded federal mail fraud statutes do not fall within the § 921(a)(20)(A) exemption. Beth Israel Med. Ctr., 576 F.Supp. at 1066 (“... as several New York cases have observed, § 190.65 is modelled on the federal mail fraud statute....”); Dreher, 115 F.3d at 332-33 (<HOLDING>). Having determined that the purpose of §
holding that violations of federal mail fraud statutes in no way depend on whether they have an effect upon competition and therefore are not exempt under  921a20a holding that property not subject to sequestration is not therefore exempt holding direct misrepresentations were not required for mail fraud conviction holding that wire and mail fraud statutes are construed identically holding that a state securities claim which alleged federal mail wire and securities violations as the predicate acts did not arise under federal law and thus did not create federal jurisdiction