https://www.mondaq.com/unitedstates/personal-injury/1282218/availability-of-rico-claims-to-foreign-holders-of-arbitral-awards
The Third Circuit weighed in several months later. In a case involving an alleged RICO enterprise to bribe foreign officials and harm the plaintiff's business interests, including its goodwill and reputation, the Third Circuit rejected the Seventh Circuit's residence-based approach. It instead determined that "whether an alleged injury to an intangible interest was suffered domestically is a particularly fact-sensitive question requiring consideration of multiple factors"4 and outlined several such factors. Because harm to the foreign-plaintiff's business occurred mainly abroad, the Third Circuit determined the foreign-plaintiff had not suffered a domestic injury.