Computer Concepts, Inc. v. Brandt

This case arises under the Oregon Securities Law, ORS 59.005 to 59.370, and the Oregon Racketeer Influenced and Corrupt Organization Act, ORS 166.715 to 166.735 (ORICO). The trial court granted summary judgment to defendants on the securities law claim, on the ground that the transaction did not involve the sale of a security. The court also dismissed plaintiffs’ ORICO claim with prejudice, apparently because they did not allege criminal convictions as predicate acts and because they did not allege “continuity” of defendants’ enterprise.

The Court of Appeals reversed, holding that there is an…