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The judge overseeing this long-running litigation, Nicholas Garaufis, gave the Europeans one more chance to refine their complaint but dismissed it yet again in 2011, calling it a structureless morass of allegations, devoid of any sequential description of events. The Second Circuit reversed that decision in 2014 on the narrow grounds that Garaufis had gone too far by declaring RICO applies only to enterprises that operate primarily in the U.S

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