Coordinated Theft, But Not Racketeering

In D&T Partners LLC v. Baymark Partners Mgmnt., LLC, “[a] group of individuals allegedly sought to steal the assets and trade secrets of an e-commerce company,” and “did so with shell entities, corrupt lending practices, and a fraudulent bankruptcy.” The plainitffs’ complaint did not state a RICO claim, however:

“While the complaint alleges coordinated theft, the alleged victims are limited in number, and the scope and nature of the scheme was finite and focused on a singular objective. … [T]his does not constitute a “pattern” of racketeering conduct sufficient to state a RICO claim ….”

No. 22-11148 (Apr. 4, 2024).