What is the appropriate standard for assessing a direct relation between the injury asserted and the injurious conduct alleged under RICO, and can proximate cause be established when the defendant's RICO violation harms a plaintiff who is not the specific target of the underlying criminal act?

QUESTIONS PRESENTED The Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. §§ 1962 et seq., creates a civil action for “[a]ny person injured in his business or property by reason of’ its predicate offenses. 18 U.S.C. §1964(c). This Court has interpreted “by reason of’ to require “some direct relation between the injury asserted and the injurious conduct alleged.” Bridge v. Phx. Bond & Indem. Co., 553 U.S. 639, 654 (2008). The questions presented are: 1. What is the appropriate standard for assessing a direct relation between the injury asserted and the injurious conduct alleged under RICO? 2. Can proximate cause under RICO be established when the defendant’s RICO violation harms a plaintiff who is not the specific target of the underlying criminal act? ii RULE 29.6 DISCLOSURE STATEMENT Petitioner Petrobras America, Inc. is a wholly owned subsidiary of Petrobras International Braspetro BV, which is a wholly owned subsidiary of Petréleo Brasileiro S.A. Petréleo Brasileiro S.A. is the state oil company of Brazil. No publicly held company owns 10 percent or more of the stock of Petrobras America, Inc.