What is the current state of the law in relation to RICO?

RICO makes it criminal "to conduct" an "enterprise's affairs through a pattern of racketeering activity." 18 U.S.C. 1962(c). A person injured by a RICO violation may bring a civil RICO action. 1964(c). "To state a claim under 1962(c), a plaintiff must allege (1) conduct (2) of an enterprise (3) through a pattern (4) of racketeering activity. [Citation.] A pattern requires at least two acts of racketeering activity. 18 U.S.C. 1961(5). 'Racketeering activity' is any act indictable under several provisions of Title 18 of the United States Code, and includes the predicate acts of mail fraud, wire fraud and obstruction of justice." Sanford v. MemberWorks, Inc., 625 F.3d 550, 557 (9th Cir. 2010) (internal citations omitted).