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    Filed August 11, 2000
    
    UNITED STATES COURT OF APPEALS
    FOR THE THIRD CIRCUIT
    
    No. 99-1854
    
    JOSEPH MAIO; JO ANN MAIO; and GARY BENDER, ON
    BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY
    SITUATED
    
    v.
    
    AETNA INC.; AETNA-US HEALTHCARE, INC; AETNA-U.S.
    HEALTHCARE OF ARIZONA INC.; AETNA-U.S.
    HEALTHCARE OF CALIFORNIA INC.; AETNA-U.S.
    HEALTHCARE INC. (COLORADO); AETNA HEALTH PLANS
    OF SOUTHERN NEW ENGLAND, INC.; AETNA-U.S.
    HEALTHCARE, INC. (DELAWARE); AETNA-U.S.
    HEALTHCARE INC. (FLORIDA); AETNA-U.S. HEALTHCARE
    OF GEORGIA INC.; AETNA-U.S. HEALTHCARE OF
    ILLINOIS; AETNA-U.S. HEALTHCARE INC. (KENTUCKY);
    AETNA-U.S. HEALTHCARE INC. (LOUISIANA); AETNA-U.S.
    HEALTHCARE INC. (MASSACHUSETTS); AETNA-U.S.
    HEALTHCARE INC. (MICHIGAN); AETNA-HEALTH PLANS
    OF NEW JERSEY, INC.; AETNA-U.S. HEALTHCARE INC.
    (NEW YORK); AETNA-U.S. HEALTHCARE OF THE
    CAROLINAS; AETNA-U.S. HEALTHCARE INC. (OHIO);
    AETNA-U.S. HEALTHCARE INC. (PENNSYLVANIA); AETNA
    HEALTH PLANS OF CENTRAL AND EASTERN
    PENNSYLVANIA, INC.; AETNA HEALTH PLANS OF
    WESTERN PENNSYLVANIA, INC; AETNA HEALTH PLANS
    OF TENNESSEE, INC.; AETNA-U.S. HEALTHCARE INC.
    (TEXAS); AETNA-U.S. HEALTHCARE OF NORTH TEXAS
    INC.; AETNA-U.S. HEALTHCARE INC. (VIRGINIA); AETNA-
    U.S. HEALTHCARE OF WASHINGTON INC.
    
    JOSEPH MAIO; JO ANN MAIO; GARY BENDER,
    
           Appellants
    
    
    
    
    On Appeal from the United States District Court
    for the Eastern District of Pennsylvania
    (D.C. Civ. No. 99-1969)
    District Judge: Honorable John P. Fullam
    
    Argued June 19, 2000
    
    BEFORE: GREENBERG and WEIS, Circuit Judges,
    SCHWARTZ,* District Judge
    
    (Filed: August 11, 2000)
    
    Edith M. Kallas (argued)
    David J. Bershad
    Patricia M. Hynes
    Charles S. Hellman
    Milberg Weiss Bershad Hynes
     & Lerach LLP
    One Pennsylvania Plaza
    49th Floor
    New York, New York 10119
    
    James J. Binns
    The Mellon Bank Center
    39th Floor
    1735 Market Street
    Philadelphia, Pennsylvania 19103
    Harvey Rosenfield
    The Foundation for Taxpayer and
     Consumer Rights
    1750 Ocean Park Boulevard
    Suite 200
    Santa Monica, California 90405
    _________________________________________________________________
    
    * Hon. Murray M. Schwartz, Senior Judge of the United States District
    Court for the District of Delaware, sitting by designation.
    
                                    2
    
    
           Eugene A. Spector
           Jeffrey L. Kodroff
           Andrew Abramowitz
           Spector & Roseman, P.C.
           1818 Market Street
           Suite 2500
           Philadelphia, Pennsylvania 19103
    
            Attorneys for Appellants
    
           Alan J. Davis (argued)
           Burt M. Rublin
           Raymond A. Quaglia
           Ballard Spahr
           Andrews & Ingersoll, LLP
           1735 Market Street, 51st Floor
           Philadelphia, Pennsylvania
            19103-7599
    
            Attorneys for Appellees
    
    OPINION OF THE COURT
    
    GREENBERG, Circuit Judge
    
    I. INTRODUCTION
    
    This matter comes before this court on an appeal by
    Joseph Maio, Jo Ann Maio and Gary Bender (hereinafter
    "appellants") from the district court's final order entered
    September 29, 1999, which granted motions to dismiss
    appellants' complaint pursuant to Fed. R. Civ. P. 12(b)(1),
    12(b)(6) and 9(b). In their "class action complaint,"
    appellants asserted claims against Aetna, Inc., Aetna-U.S.
    Healthcare, Inc., and Aetna-U.S. Healthcare, Inc.'s 24
    regional subsidiary health plans (collectively "Aetna" or
    "appellees") for violations of the Racketeer Influenced and
    Corrupt Organizations Act ("RICO"), 18 U.S.C.S 1961 et
    seq., and state law. The appellants describe this case as
    challenging "Aetna's failure to disclose its restrictive and
    coercive internal policies and practices, which render its
    advertising, marketing and membership materials false and
    
                                    3
    
    
    misleading in violation of RICO." Br. at 4. Appellants allege
    that "Aetna has engaged in a massive nationwide
    fraudulent advertising campaign designed to induce people
    to enroll in its HMO by representing that Aetna
    affirmatively manages its members' health care so as to,
    inter alia, raise the quality of care to a `level of health care
    never available under the old fee-for-service system,' " when
    in fact, Aetna designed undisclosed internal policies to
    "improve defendants' profitability at the expense of quality
    of care." Br. at 4-5 (footnote omitted). Appellants seek
    compensatory damages and an injunction enjoining
    appellees from pursuing the "policies, acts and practices"
    alleged in the complaint, together with punitive damages,
    treble damages, and attorney's fees under RICO.
    
    Prior to filing an answer to the complaint, the appellees
    filed sequential motions to dismiss. In its Memorandum
    and Order of September 29, 1999, see Maio v. Aetna, Inc.,
    No. 99-1969, 1999 WL 800315 (E.D. Pa. Sept. 29, 1999),
    the district court determined that appellants' RICO claims
    in counts I and II of the complaint failed because appellants
    did not allege that they suffered a concrete "injury in fact"
    sufficient to confer standing on them to challenge Aetna's
    allegedly fraudulent activities. Accordingly, the district
    court entered an order granting the appellees' motions
    insofar as they pertained to appellants' RICO claims, and
    thus dismissed with prejudice counts I and II of the
    complaint, the RICO counts. The district court then
    dismissed the state law claims without prejudice"for lack
    of subject matter jurisdiction." Id. at *2.
    
    For the reasons that follow, we will affirm the district
    court's order dismissing the complaint on the ground that
    appellants have not alleged an injury to business or
    property cognizable under RICO.
    
    II. FACTS and PROCEEDINGS
    
    A. Factual Background
    
    We decide this appeal on the facts appellants alleged in
    their complaint. Appellants instituted this purported class
    action on behalf of themselves and all members of a class
    
                                    4
    
    
    consisting "of all persons in the United States who are, or
    were, enrolled in [Aetna's] Health Maintenance Organization
    (the `HMO') plans (the `Plan') at any time during the period
    from July 19, 1996 to the present (the `class period')."1 JA-
    14. The class allegedly consists of millions of both present
    and former Aetna HMO members who, as a group, "were
    targeted by [Aetna] and induced into enrolling in Aetna's
    HMO by virtue of defendants' standardized and uniform
    misrepresentations and omissions of material facts
    contained in advertising, marketing and membership
    materials." Id. Appellants aver that during the class period,
    Aetna engaged in a fraudulent scheme designed to induce
    individuals to enroll in its HMO plan by representing "that
    its primary commitment, in connection with the healthcare
    services provided to its HMO members, is to maintain and
    improve the quality of care given to such members and that
    defendants' policies are designed to accomplish these
    goals." JA-14.
    
    Appellants also assert that Aetna represented that HMO
    members would receive high quality health care from
    physicians who are solely responsible for providing all
    medical care and maintaining the physician-patient
    relationship, when in reality Aetna's internal policies
    restrict the physicians' ability to provide the high quality
    health care that appellants have been promised. JA-15.
    Moreover, they claim that despite Aetna's representations
    that it compensated its physicians under a system that
    provides them with incentives based upon the quality of
    care provided, Aetna's provider contracts actually offer the
    physicians financial incentives to withhold medical services
    and reduce the quality of care to HMO members. Id.
    
    The complaint alleges that Aetna made these various
    representations through marketing, advertising and
    membership materials distributed to each and every
    _________________________________________________________________
    
    1. For convenience, we will refer to Aetna-U.S. Healthcare, Inc.'s HMO
    plan as "Aetna's HMO." See JA-21, JA-27. Aetna's HMO is an individual
    practice association model HMO in which Aetna contracts with
    physicians, groups of physicians, and medical centers who agree to
    provide care to HMO members in addition to other, non-HMO affiliated
    patients. JA-27.
    
                                    5
    
    
    prospective enrollee including the appellants. JA-29. The
    complaint provides several examples of Aetna's
    advertisements during the class period, each of which
    appellants claim reaffirmed in some manner Aetna's
    supposed commitment to "raising the quality of healthcare
    in America." See JA-29 to JA-34. Similarly, the complaint
    refers to certain membership materials, including a
    brochure entitled "HMO Plan Benefits," and avers that the
    brochure represented that Aetna provides financial
    incentives "intended to continually improve medical care,"
    see JA-35, when in reality, the financial incentives were
    intended to have just the opposite effect--i.e., to restrict the
    level of health care that the participants received.
    
    The complaint further points to the "HMO Plan Member
    Handbook" and the "Certificate of Coverage," and alleges
    that Aetna falsely represented therein that the health care
    administered under the HMO is entrusted solely to Aetna-
    affiliated physicians and individual practice associations.
    Appellants claim essentially that these representations
    created an illusion that the physicians would make the
    necessary decisions regarding patient care independently,
    when in reality Aetna's policies restricted the physicians'
    decisionmaking abilities concerning the level and extent of
    care to be provided in particular cases. Appellants argue
    specifically that the HMO Plan Member Handbook explicitly
    states that (1) "Participating Physicians maintain the
    physician-patient relationship with Members and are solely
    responsible to Member for all Medical Services which are
    rendered by Participating Physicians"; (2) "Understand that
    participating doctors and other health care providers who
    care for you are not employees of the HMO and that the
    HMO does not control them"; and (3) HMO members have
    the right to "[h]elp your doctor make decisions about your
    health care." See JA-35 (alteration in original); JA-321 to
    JA-322; Br. at 11.2
    _________________________________________________________________
    
    2. Appellants' brief recites other representations made in the Handbook,
    claiming that they were false and misleading. Br. at 11 (noting that the
    Handbook states that "when medically necessary, your primary care
    physician may refer you to a specialist or facility for treatment or for
    covered preventative care services," and further stating that "members
    have a right to `have a doctor decide when coverage treatment should be
    denied.' "); see also JA-330, JA-340. Because these statements are not
    mentioned in the complaint, we need not consider them in our analysis,
    although if we did our result would be the same.
    
                                    6
    
    
    Appellants also claim that appellees falsely represented in
    other membership documents that physicians would be
    awarded for providing quality care, when in reality the
    physicians were rewarded under Aetna's plan based on how
    well they minimized costs. Appellants first point to the
    HMO Plan Member Handbook as well as the "Physician and
    Hospital Directory" and contend that appellees represented
    therein that in order to ensure that HMO members receive
    high quality care, physicians are compensated under a
    system that provides them with incentives based upon the
    quality of care provided:
    
           Primary care physicians are generally compensated in
           accordance with our Quality Care Compensation
           System, which rewards primary care physicians for
           delivery of quality care in a cost-effective manner . This
           includes payment on a per member per month basis
           (capitation), as well as quality incentives to enhance
           patient satisfaction, improve medical care, and
           participate in continuing medical education programs.
           Also a small component of overall compensation reflects
           how effectively the physician manages the cost of the
           hospital and specialist services and provides effective
           preventative care.
    
    JA-36 to JA-37 (alteration in original). Appellants also rely
    on representations made in appellees' brochure entitled
    "How We Measure Quality," in which appellees allegedly
    convey that physicians are compensated "based upon
    quality of care considerations." JA-36. Appellants rely on
    the following statements in the brochure:
    
           Aetna-U.S. Healthcare has been recognized as the
           industry leader in using information about the quality
           of care and service provided to members to help
           determine how primary care physicians are paid. Our
           incentives are directed to reward better quality care and
           to guard against any potential to withhold care. This
           innovative payment method, the Quality Care
           Compensation System (QCCS) is in the process of
           being extended to Aetna-U.S. Healthcare participating
           physicians across the nation.
    
           QCCS rewards primary care physicians for delivering
           quality care in a cost-effective manner. This includes
    
                                    7
    
    
           paying primary care physicians on a per member per
           month basis (capitation), as well as providing quality
           incentives to satisfy patients, improve medical care  and
           participate in continuing medical education programs.
    
           In particular, QCCS can positively influence care by
           rewarding primary care physicians whose charts reflect
           their attention to quality preventative medicine. This
           includes taking a thorough medical history of the
           patient, providing immunizations and cholesterol
           testing, and properly recording the physician'sfindings.
           Member survey results are also considered because we
           value the opinions expressed by our members about
           the quality of care and service they receive from their
           primary care physicians. Also a small portion  of the
           total compensation reflects how effectively the
           physician manages the cost of hospital and specialist
           services and provides effective preventative care.
    
    JA-36 to JA-37. Appellants further point out that the
    brochure concludes by stating:
    
           This brief introduction to the Quality Improvement
           Program at Aetna-U.S. Healthcare demonstrates why
           we believe no other managed care organization
           embraces quality as intensively as we do. We are
           accumulating extensive information on the care
           received by our 10.8 million managed care members.
           Our commitment to quality improvement enables us to
           deliver health care plans that are readily distinguished
           from the rest of this industry.
    
    JA-37.
    
    According to appellants' complaint, despite the
    representations appellees made in their advertising,
    marketing and membership materials, they failed to
    disclose certain of their internal policies which contradict
    the message conveyed to appellants that quality care was
    Aetna's primary concern. JA-38. Aetna's allegedly
    undisclosed internal policies include: (1) generating
    agreements with medical service providers which restrict
    the ability of Aetna's physicians to provide quality care; (2)
    providing financial incentives to physicians which are
    intended to reduce the quality of care provided to plan
    
                                    8
    
    
    members rather than raise the quality of care; and (3)
    providing disparate treatment to HMO members who
    receive benefits under a plan subject to the Employee
    Retirement Income Security Act ("ERISA") versus non-
    ERISA HMO members. JA-38.
    
    The class action complaint provides the following
    examples of Aetna's "systemic policies" with respect to the
    provider agreements between Aetna and the participating
    physicians which allegedly inhibit the physicians' abilities
    to provide quality care to Aetna's HMO members:
    
           - Aetna's policy of `removing the medical decision-
           making process from the plan members' physicians
           and giving it to Aetna-USHC, despite the fact that
           defendants represent in the marketing and
           advertising material they distribute to prospective
           enrollees that physicians are solely responsible for
           all medical services provided.'
    
           - Aetna's decision to define the term `medical
           necessity' `in an extremely narrow fashion that
           focuses minimally on clinical medicine and focuses
           largely on cost and convenience to the plan.'
    
           - Aetna's policy which permits it `to override a
           physician's decisions about what care is medically
           necessary' and its failure `to provide a mechanism
           for physicians to appeal a decision by Aetna that
           patient care is not deemed medically necessary--
           even though defendants represent in their
           marketing material that physicians cannot be
           penalized for filing a complaint or an appeal.'
    
           - Aetna's policy of including `gag' clauses in provider
           contracts that allegedly limit physicians' ability to
           disclose information to patients.
    
           - Aetna's policy of `refusing to negotiate with
           individual physicians contract provisions that
           [allegedly] implicate serious concerns regarding
           patient care.'
    
           - Aetna's decision to retain `the power to amend,
           unilaterally, all terms of their contract, including
    
                                    9
    
    
           clinical protocols and procedures, without any
           requirement that Aetna notify physicians.'
    
           - Aetna's policy of purportedly restricting patient
           access to emergency care services.
    
           - Aetna's policy of providing an `open-ended definition
           of emergency care which [allegedly] fails to
           incorporate a prudent layperson standard or in any
           way make clear what kind of treatment options a
           patient will receive under the plan when they
           reasonably seek emergency services.'
    
           - Aetna's policy which gives the Plan co-ownership of
           patient medical records which violates, according to
           plaintiffs, physician-patient confidentiality.
    
    JA-39 to JA-40. Appellants claim that Aetna "fail[ed] to
    disclose the existence of these restrictive agreements with
    physicians, despite the fact that [Aetna] represent[ed] in
    their marketing materials that plan members have the right
    to know how Aetna-USHC decides what services are
    covered." JA-39.
    
    Appellants also describe in their complaint the nature of
    Aetna's purportedly undisclosed financial incentives
    provided to physicians which allegedly were designed to
    reduce the quality of care provided to its HMO members:
    
           - `incentives and disincentives which seek to reward
           physicians for achieving large patient/member
           ratios. For example, physicians are rewarded for a
           patient/member ratio which exceeds 750 patients
           per provider.'
    
           - `incentives and disincentives which seek to restrict
           HMO members' hospitalization, specialist and
           emergency room utilization.'
    
           - `quality factored distributions which reward
           physicians for attaining specific performance
           utilization targets for acute hospitalization care,
           catastrophic specialist utilization and emergency
           room utilization.'
    
    JA-40 (internal quotation marks omitted).
    
                                    10
    
    
    Appellants also challenge Aetna's failure to disclose its
    policy of "disparately treating individuals who receive their
    benefits through ERISA plans (where liability may be
    limited to statutory remedies) versus those who receive
    their benefits through non-ERISA plans (where liability may
    be much greater)." Br. at 16; see also JA-50. The complaint
    alleges that an internal Aetna videotape concerning its
    disability insurance claims handling practice records Aetna
    representatives' directions to its employees to"do more on
    a non-ERISA plan to protect against the potential for
    exposure to litigation, thereby discriminating against ERISA
    beneficiaries." JA-50 to JA-51 (internal quotation marks
    omitted). The complaint further avers that "[a]lthough the
    training video dealt with the handling of long-term
    disability claims, an Associated Press article dated October
    12, 1998, . . . stated that while the topic of the video was
    long-term disability claims and not health insurance, `the
    company says that its policies do not differ.' " JA-53 to JA-
    54. Appellants state that "[s]uch a policy also evidences
    [Aetna's] intention to provide only the most minimal, not
    quality healthcare services to all its HMO members." JA-54.
    
    Count I of appellants' complaint alleges that Aetna's
    conduct violated RICO sections 1962(c) and (d), and count
    II states a claim predicated on RICO sections 1962(a) and
    (d).3 Counts III through V assert claims arising under
    _________________________________________________________________
    
    3. 18 U.S.C. S 1962 provides in pertinent part:
    
            (a) It shall be unlawful for any person who ha s received any
           income derived, directly or indirectly, from a pattern of racketeering
           activity or through collection of an unlawful debt in which such
           person has participated as a principal within the meaning of section
           2, title 18, United States Code, to use or invest, directly or
           indirectly, any part of such income, or the proceeds of such income,
           in acquisition of any interest in, or the establishment or operation
           of, any enterprise which is engaged in, or the activities of which
           affect, interstate or foreign commerce. A purchase of securities on
           the open market for purposes of investment, and without the
           intention of controlling or participating in the control of the issuer,
           or of assisting another to do so, shall not be unlawful under this
           subsection if the securities of the issuer held by the purchaser, the
           members of his immediate family, and his or their accomplices in
           any pattern or racketeering activity or the collection of an unlawful
    
                                    11
    
    
    Pennsylvania law (Count III--Fraud and Deceit; Count IV--
    Pennsylvania Unfair Trade Practices and Consumer
    Protection Law--"and Other Similar Consumer Protection
    Statutes"; Count V--Unjust Enrichment).
    
    Section IV of the complaint, which is entitled
    "Appropriateness of Class Treatment," not only provides a
    summary of the legal theory upon which appellants
    predicate their federal and state claims, but also states
    explicitly those theories upon which appellants' claims are
    not based:
    
           In addition, this action does not seek to remedy claims
           of personal injury, contract, denial of benefits, medical
           malpractice and/or wrongful death against defendants.
           Moreover, this action seeks to remedy claims
           addressing the quality of healthcare services as set
           forth in Dukes v. U.S. Healthcare, Inc., 57 F.3d 350 (3d
           Cir. 1995), and its progeny, and does not seek to
           recover benefits due under the terms of a plan, to
           enforce rights under the terms of a plan or to clarify
           rights to future benefits under the plan.
    
    JA-25.
    
    In accordance with their stated intention to challenge
    only the quality of health care services that Aetna arranged
    for and provided through its participating physicians,
    appellants allege that as a result of Aetna's adoption of the
    systemic polices and practices outlined in the complaint,
    "the healthcare provided to plaintiffs and the Class is not as
    _________________________________________________________________
    
           debt after such purchase do not amount in the aggregate to one
           percent of the outstanding securities of any one class, and do not
           confer, either in law or in fact, the power to elect one or more
           directors of the issuer.
    
            (c) It shall be unlawful for any person employ ed by or associated
           with any enterprise engaged in, or the activities of which affect,
           interstate or foreign commerce, to conduct or participate, directly or
           indirectly, in the conduct of such enterprise's affairs through a
           pattern of racketeering activity or collection of unlawful debt.
    
            (d) It shall be unlawful for any person to con spire to violate any
           of the provisions of subsection (a), (b), or (c) of this section.
    
                                    12
    
    
    represented in their uniform marketing, advertising and
    membership materials." According to appellants,"the
    substantial difference in the quality of healthcare services
    marketed by defendants, and the quality of healthcare
    services actually provided to plaintiffs and the Class, cause
    membership in the Plan to be worth much less than that
    actually charged by defendants, and have ultimately
    resulted in damages to plaintiffs and the Class." JA-54.
    They also explain that "[p]laintiffs and the members of the
    Class enrolled in Aetna's HMO Plans paid periodic
    premiums to defendants as a result of defendants'
    fraudulent practices" and therefore have "been injured in
    their business and/or property by defendants' racketeering
    activity in amounts to be determined at trial." JA-58.
    
    B. Procedural History
    
    Appellants filed their complaint in the district court on
    April 19, 1999. JA-1. As we previously mentioned, the
    appellees filed sequential motions to dismiss pursuant to
    Fed. R. Civ. P. (hereinafter "Rule") 12(b)(1), 12(b)(6) and
    9(b), arguing that appellants' complaint was subject to
    dismissal for several reasons. As described by the district
    court, Aetna first argued that appellants lacked standing to
    sue under RICO. It argued that, while appellants claim that
    because of its actions the quality of care "will suffer and/or
    their HMO plans are worth less than they cost, no one
    claims to have been injured by being denied necessary
    care." Maio, 1999 WL 800315, at *1. In other words, as we
    interpret the appellees' argument, they claimed that
    appellants failed to allege facts which demonstrate that
    appellants suffered a cognizable injury "to business or
    property," which is a necessary element of a civil RICO
    claim.
    
    Second, Aetna claimed that any injury appellants might
    have suffered as a consequence of the fraud was indirect at
    best and that the complaint therefore failed to allege
    sufficient factual information supporting the inference that
    appellants' injuries were proximately caused by appellees'
    allegedly fraudulent conduct. Third, appellees asserted that
    appellants' RICO counts failed to state a claim because the
    appellees' allegedly fraudulent statements about"quality of
    
                                    13
    
    
    care" which constituted the basis for appellants' allegations
    of racketeering activity, were nothing more than"mere
    puffery" and therefore were not actionable. In any event,
    the appellees claimed that they did not commit any fraud
    against the appellants because the policies and contract
    information that they allegedly concealed from the
    appellants in fact were disclosed fully to the public. Fourth,
    appellees contended that appellants failed to plead a valid
    RICO enterprise (for purposes of count I under section
    1962(c)), and also failed to allege any injury resulting from
    the investment or use of alleged racketeering income (for
    purposes of count II under section 1962(a)). Finally,
    appellees argued that appellants' RICO claims were
    preempted by ERISA, the Federal Employee Health Benefits
    Act ("FEHBA"), and the Medicare Act, and alternatively were
    precluded by the application of the McCarran-Ferguson Act.
    See id. Appellants responded to appellees' arguments, and
    specifically requested in their opposition brief the
    opportunity to amend the complaint to cure any pleading
    deficiencies that the district court might find.
    
    As previously mentioned, the district court dismissed
    appellants' RICO claims (pleaded in counts I and II) on the
    merits and declined to exercise supplemental jurisdiction
    over their state law claims (pleaded in counts III-V).4 The
    primary basis for the district court's dismissal of the RICO
    claims was what it perceived to be appellants' lack of a
    concrete "injury-in-fact" sufficient to confer standing upon
    them.5 After citing the constitutional standing requirements
    _________________________________________________________________
    
    4. The order actually states that the state law claims were dismissed
    "FOR LACK OF SUBJECT MATTER JURISDICTION," see Appellants' br.,
    app. at 6, but the district court's opinion clarifies that it intended to
    decline, in its discretion, to exercise supplemental jurisdiction over the
    remaining non-federal claims as provided in 28 U.S.C. S 1367(c)(3).
    
    5. We note parenthetically that neither the district court nor the parties
    addressed the fact that the complaint actually pleads violations of three
    different subsections of 18 U.S.C. S 1962. See note 3, supra. As
    previously mentioned, count I states that the appellees' conduct violated
    sections 1962(c) and (d), and count II alleges that their conduct violated
    sections 1962(a) and (d). Obviously, given that the district court
    dismissed the RICO claims primarily because it found that appellants
    failed to allege any RICO injury to property under section 1964(c), it was
    
                                    14
    
    
    the Supreme Court articulated in Lujan v. Defenders of
    Wildlife, 504 U.S. 555, 560, 112 S.Ct. 2130, 2136 (1992),
    the district court reasoned that the allegations in
    appellants' complaint belied their assertion that they
    suffered any concrete economic injury stemming from
    appellees' allegedly fraudulent conduct:
    
           Plaintiffs claim to have been injured in that they were
           fraudulently induced to enroll in the HMOs as a result
           of Aetna's representation that it is primarily concerned
           with quality of care. Because defendants are allegedly
           more interested in profits and cost containment,
           plaintiffs contend that they have paid more for their
           HMO plans than those plans are worth. As noted
           above, however, plaintiffs disclaim any injury due to
           the denial of benefits, reduction of benefits, inferior
           care, malpractice, negligence or breach of contract--in
           short, plaintiffs have disclaimed any injury that has
           the potential to decrease the value of defendants'
           plans. The HMOs simply cannot be `worth less' unless
           something plaintiffs were promised was denied them. A
           vague allegation that `quality of care' may suffer in the
           future is too hypothetical an injury to confer standing
           upon plaintiffs, and in addition, would require this
           court to assume that in every case, individual
           physicians and [individual practice associations] will be
           moved to put their own economic interests ahead of
           their patients' welfare. Even if this were the inevitable
           result, defendants would not be the proximate cause of
           the providers' ethical lapses. See Weiss v. CIGNA
           Healthcare, Inc., 972 F. Supp. 748, 752 (S.D.N.Y.
           1996).
    
    Maio, 1999 WL 800315, at *2.
    
    While the court noted that it did not have to address the
    remainder of Aetna's arguments in support of dismissal, it
    _________________________________________________________________
    
    unnecessary for the court to address the two counts separately.
    Inasmuch as we also have determined that appellants' RICO claims are
    deficient because they fail to allege facts which, if established, would
    prove the damages element under RICO, our analysis treats the separate
    federal claims as one.
    
                                    15
    
    
    nevertheless held in the alternative that appellants'
    complaint failed to plead a valid RICO enterprise, and also
    that it was "highly doubtful that advertising one's
    commitment to `quality of care' can serve as the predicate
    for a fraud claim." Id. The court concluded its discussion of
    appellants' RICO claim by observing that "plaintiffs'
    expression of dissatisfaction with defendants' plans--indeed
    with HMOs in general--is more appropriately directed to
    the legislatures and regulatory bodies of the several states."
    Id. Ultimately, the court entered an order dismissing
    appellants' RICO claims with prejudice, without specifically
    addressing their request for leave to amend the complaint.6
    Appellants filed a timely notice of appeal on October 26,
    1999.
    
    III. JURISDICTION and STANDARD OF REVIEW
    
    The district court exercised jurisdiction over appellants'
    RICO claims pursuant to 28 U.S.C. S 1331, and over the
    supplemental state law claims under 28 U.S.C. S 1367. We
    have appellate jurisdiction under 28 U.S.C. S 1291 to review
    the district court's final order of September 29, 1999.
    
    In reviewing a district court's dismissal of a complaint
    pursuant to Rule 12(b)(6) for failure to state a claim upon
    which relief may be granted, our review is plenary and we
    apply the same test as the district court.7 "A motion to
    (Text continued on page 18)
    _________________________________________________________________
    
    6. The district court also addressed and denied appellees' motion for
    sanctions pursuant to Fed. R. Civ. P. 11. This aspect of the district
    court's order is not at issue on this appeal. Similarly, appellants do not
    challenge specifically the district court's dismissal of their state law
    claims without prejudice pursuant 28 U.S.C. S 1367(c)(3). Rather, their
    argument apparently is that in the event that we reverse the district
    court's dismissal of their RICO claims and remand for further
    proceedings, we should order that the district court reinstate their state
    law claims on remand. Given the result we reach on the federal claims,
    the district court acted well within its discretion in dismissing
    appellants' state law claims pursuant to 28 U.S.C.S 1367(c)(3).
    Accordingly, we will not address the issue in any further detail.
    
    7. Preliminarily, we point out that we have not overlooked the fact that
    appellees moved to dismiss on standing grounds pursuant to Rule
    12(b)(1), claiming that the nature of appellants' injury allegations
    
                                    16
    
    
    demonstrated that they suffered no cognizable "injury in fact" under
    section 1964(c) of RICO, and therefore that the district court lacked
    subject matter jurisdiction over appellants' federal claims pursuant to
    Article III of the United States Constitution. See Aetna's Br. in Supp. of
    Mot. to Dismiss at 12 (no. 3 on district court docket). Given that the
    district court's order did not state whether it was dismissing the RICO
    claims under Rule 12(b)(1) or Rule 12(b)(6), the legal basis for the court's
    ruling is unclear. The court's ambiguity on this point, in turn, raises the
    question of whether the order should have been denominated a dismissal
    under Rule 12(b)(6) or Rule 12(b)(1), given that the basis for the court's
    ruling was a perceived lack of RICO injury "to business or property"
    sufficient to confer "standing" to sue under section 1964(c). Generally
    speaking, motions to dismiss on the grounds of a failure to allege an
    "injury in fact" implicate constitutional standing principles and thus are
    predicated on Rule 12(b)(1) rather than Rule 12(b)(6). See, e.g., Society
    Hill Towers Owners' Ass'n v. Rendell, 210 F.3d 168, 175 (3d Cir. 2000)
    (defendants challenged plaintiffs' standing pursuant to motion to dismiss
    under Rule 12(b)(1)). And in view of the district court's statement that
    appellants' allegations failed to demonstrate an"injury in fact," it
    appears as if the court's dismissal was pursuant to Rule 12(b)(1) for lack
    of subject matter jurisdiction rather than under 12(b)(6) for failure to
    state a claim.
    
    While we have designated section 1964(c) as the"standing" provision
    of RICO, see Brokerage Concepts, Inc. v. U.S. Healthcare, Inc., 140 F.3d
    494, 520-21 (3d Cir. 1998), we point out that our method of analysis in
    prior cases has been to consider issues of RICO and antitrust standing
    in the context of reviewing motions to dismiss pursuant to Rule 12(b)(6),
    despite the fact that the "injury to business or property" and proximate
    causation requirements are considered aspects of the plaintiff 's
    "standing" to sue under section 1964(c) of RICO and section 4 of the
    Clayton Act. See, e.g. Steamfitters Local Union No. 420 Welfare Fund, 171
    F.3d 912, 919, 921 (3d Cir. 1999) (stating that it is appropriate to
    consider proximate cause requirement in section 1964(c) under the
    rubric of the standing doctrine and addressing the proximate causation
    issue, a separate requirement in section 1964(c), in the context of
    reviewing district court's dismissal pursuant to Fed. R. Civ. P. 12(b)(6)),
    cert. denied, ___ U.S. ___, 120 S.Ct. 844 (2000); see also In re: Warfarin
    Sodium Antitrust Litig., 214 F.3d 395, 397-99 (3d Cir. 2000) (addressing
    antitrust standing concepts in context of reviewing motion to dismiss
    pursuant to Rule 12(b)(6)); City of Pittsburgh v. West Penn Power Co.,
    147 F.3d 256, 264 (3d Cir. 1998) (same); compare DeMauro v. DeMauro,
    115 F.3d 94, 96 (1st Cir. 1997) (reviewing standing issue under 1964(c)
    
                                    17
    
    
    dismiss pursuant to Rule 12(b)(6) may be granted only if,
    accepting all well-pleaded allegations in the complaint as
    true, and viewing them in the light most favorable to
    plaintiff, plaintiff is not entitled to relief." In re Burlington
    Coat Factory Sec. Litig., 114 F.3d 1410, 1420 (3d Cir. 1997)
    (citing Bartholomew v. Fischl, 782 F.2d 1148, 1152 (3d Cir.
    1986)). " `The issue is not whether a plaintiff will ultimately
    _________________________________________________________________
    
    based on allegations in the pleadings; court noted in passing that
    "[t]here is plainly a case or controversy under Article III; but the
    statutory precondition of injury to business or property must be met.");
    Oscar v. University Students Co-Operative Ass'n, 965 F.2d 783, 784-87
    (9th Cir. 1992) (en banc) (addressing RICO injury requirement set forth
    in section 1964(c) in context of reviewing district court's dismissal
    pursuant to Rule 12(b)(6); cf. Associated General Contractors of Cal., Inc.
    v. California State Council of Carpenters, 459 U.S. 519, 529, 103 S.Ct.
    897, 903-04 (1983) (addressing proximate causation requirement in
    analogous provision found in section 4 of the Clayton Act; proximate
    causation is but one aspect of "antitrust standing" and the Court
    addressed plaintiff 's standing to sue in context of reviewing motion to
    dismiss pursuant to Rule 12(b)(6)). But see Moore v. PaineWebber, Inc.,
    189 F.3d 165, 169 n.3 (2d Cir. 1999) ("Because loss causation is an
    element of standing to sue under the RICO statute, the appropriate
    ground for dismissal for failure to plead loss causation would seem to be
    the lack of subject matter jurisdiction rather than the plaintiffs' failure
    to state a claim.").
    
    While we appreciate the distinction between a dismissal for lack of
    subject matter jurisdiction under Rule 12(b)(1) and a dismissal for failure
    to state a claim under Rule 12(b)(6), we need not resolve which is the
    correct approach in the context of this case, as the appellants interpret
    the dismissal as grounded on Rule 12(b)(6), see  br. at 16-17, and
    appellees have not challenged appellants' characterization in that regard.
    Inasmuch as the appellants treat the dismissal as one pursuant to Rule
    12(b)(6), there is no prejudice to appellants in our reviewing the district
    court's dismissal as if it were grounded on Rule 12(b)(6), and we will
    treat it as such. See Kehr Packages, Inc. v. Fidelcor, Inc., 926 F.2d 1406,
    1409 (3d Cir. 1991) (noting that a plaintiff may be prejudiced if what is,
    in essence, a Rule 12(b)(6) challenge to the complaint is treated as a
    Rule 12(b)(1) motion, but that there was no prejudice in treating district
    court's Rule 12(b)(1) dismissal as one predicated on Rule 12(b)(6),
    especially where plaintiffs treated it as such); see also Children's
    Seashore House v. Waldman, 197 F.3d 654, 657 n.1 (3d Cir. 1999), cert.
    denied, ___ U.S. ___, 120 S.Ct. 2742 (2000).
    
                                    18
    
    
    prevail but whether the claimant is entitled to offer
    evidence to support the claims.' " Id. (quoting Scheuer v.
    Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 1686 (1974)).
    Also we exercise plenary review over the district court's
    legal determination that appellants lacked standing to
    pursue a civil action against Aetna under section 1964(c) of
    RICO. See Stehny v. Perry, 101 F.3d 925, 929 (3d Cir.
    1996) (stating that standard of review for dismissal on
    standing grounds is plenary).
    
    IV. DISCUSSION
    
    While appellees argue that we may affirm the district
    court's order dismissing the class action complaint on a
    variety of grounds, we need address only one issue--that is,
    whether appellants have alleged a valid RICO injury to
    business or property sufficient to afford them standing
    under RICO to challenge Aetna's purportedly fraudulent
    scheme. See Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479,
    496, 105 S.Ct. 3275, 3285 (1985) (noting that a plaintiff
    "only has standing [under RICO] if, and can only recover to
    the extent that, he has been injured in his business or
    property by the conduct constituting the violation.");
    DeMauro v. DeMauro, 115 F.3d 94, 96 (1st Cir. 1997)
    (noting that threshold question of whether plaintiff made
    out a claim of "injury" to her "business or property" has
    been described as "a standing issue"); see also Brokerage
    Concepts, Inc. v. U.S. Healthcare, Inc., 140 F.3d 494, 520-
    21 (3d Cir. 1998) (stating that section 1964(c) sets forth the
    "standing requirement" applicable to suits brought under
    RICO). We reach this conclusion because, while we do not
    agree entirely with the district court's analysis on this
    point, we believe that the court's ultimate determination
    was correct in light of the facts pleaded in the complaint,
    the legal theory on which appellants' claim of financial loss
    is predicated, and the reasoning of the Supreme Court's
    recent decision in Pegram v. Herdrich, ___ U.S. ___, 120
    S.Ct. 2143 (2000).
    
    Apart from the Article III constitutional and prudential
    standing requirements which we have addressed repeatedly
    in various contexts, see, e.g., The Pitt News v. Fisher, 215
    F.3d 354, 360-62 (3d Cir. 2000) (citing Lujan , 504 U.S. at
    
                                    19
    
    
    560, 112 S.Ct. at 2136), Society Hill Towers Owners' Ass'n
    v. Rendell, 210 F.3d 168, 175-78 (3d Cir. 2000) (same),
    plaintiffs seeking recovery under RICO must satisfy
    additional standing criterion set forth in section 1964(c) of
    the statute. See DeMauro, 115 F.3d at 96 ("There is plainly
    a case or controversy under Article III; but the statutory
    precondition of injury to business or property must also be
    met."). In the RICO setting, standing is conferred upon "any
    person injured in his business or property by reason of a
    violation of section 1962 of this chapter. . . ." 18 U.S.C.
    S 1964(c).8 Extrapolating from this language, we read
    section 1964(c) as requiring a RICO plaintiff to make two
    related but analytically distinct threshold showings relevant
    in this appeal: (1) that the plaintiff suffered an injury to
    business or property; and (2) that the plaintiff 's injury was
    proximately caused by the defendant's violation of 18
    U.S.C. S 1962.9 See First Nationwide Bank v. Gelt Funding
    Corp., 27 F.3d 763, 767 (2d Cir. 1994); see Brokerage
    Concepts, 140 F.3d at 520-21 (addressing section 1964(c)'s
    proximate cause requirement in the context of standing
    analysis).
    _________________________________________________________________
    
    8. Section 1964(c) provides in its entirety:
    
           (c) Any person injured in his business or property  by reason of a
           violation of section 1962 of this chapter may sue therefor in any
           appropriate United States district court and shall recover threefold
           the damages he sustains and the cost of the suit, including a
           reasonable attorney's fee, except that no person may rely upon any
           conduct that would have been actionable as fraud in the purchase
           or sale of securities to establish a violation of section 1962. The
           exception contained in the preceding sentence does not apply to an
           action against any person that is criminally convicted in connection
           with the fraud, in which case the statute of limitations shall start to
           run on the date on which the conviction becomesfinal.
    
    9. Obviously section 1964(c) also requires a plaintiff to establish a
    violation of section 1962. See Gelt Funding Corp., 27 F.3d at 767. As
    previously mentioned, appellants' RICO claims are predicated on alleged
    violations of sections 1962(a), (c), and (d). Inasmuch as this element of
    section 1964(c) is not germane to the issues presented in this appeal, we
    will not discuss it. We further point out in passing that appellants' RICO
    claims were based on appellees' alleged predicate acts which they
    claimed violated 18 U.S.C. SS 1341, 1343, and 2314.
    
                                    20
    
    
    The Supreme Court has stated that "the plaintiff only has
    standing if, and can only recover to the extent that, he has
    been injured in his business or property by the conduct
    constituting the violation [of RICO]." Sedima, S.P.R.L., 473
    U.S. at 496, 105 S.Ct. at 3285. "As the Seventh Circuit has
    stated, `[a] defendant who violates section 1962 is not liable
    for treble damages to everyone he might have injured by
    other conduct, nor is the defendant liable to those who
    have not been injured.' " Id. at 496-97, 105 S.Ct. at 3285
    (quoting Haroco, Inc. v. American Nat'l Bank & Trust Co.,
    747 F.2d 384, 398 (7th Cir. 1984), aff 'd, 473 U.S. 606, 105
    S.Ct. 3291 (1985), which rejected a "racketeering injury"
    requirement under section 1964(c) of RICO). While the
    Supreme Court has stated generally that "RICO is to be
    read broadly," see id. at 497, 105 S.Ct. at 3285, the Court
    of Appeals for the Ninth Circuit has observed that section
    1964(c)'s limitation of RICO standing to persons"injured in
    [their] business or property" has a "restrictive significance,
    Reiter v. Sonotone Corp., 442 U.S. 330, 339, 99 S.Ct. 2326,
    2331 . . . (1979), which helps to assure that RICO is not
    expanded to provide a federal cause of action and treble
    damages to every tort plaintiff." Steele v. Hospital Corp. of
    Am., 36 F.3d 69, 70 (9th Cir. 1994) (internal quotation
    marks omitted). Thus, "a showing of injury requires proof of
    a concrete financial loss and not mere injury to a valuable
    intangible property interest." Id. (internal quotation marks
    omitted).
    
    As appellants recognize, see br. at 22-23, the injury to
    business or property element of section 1964(c) can be
    satisfied by allegations and proof of actual monetary loss,
    i.e., an out-of-pocket loss. See Steele, 36 F.3d at 70 (stating
    that plaintiffs have not suffered a financial loss under RICO
    if they have paid none of the allegedly excessive charges out
    of their own pockets); Oscar v. University Students Co-
    Operative Ass'n, 965 F.2d 783, 785 (9th Cir. 1992) (en
    banc) (injuries to property are not actionable under RICO
    unless they result in tangible financial loss to plaintiff);
    Berg v. First State Ins. Co., 915 F.2d 460, 464 (9th Cir.
    1990) (holding that plaintiffs suffered no damages under
    RICO because it was undisputed that they did not incur
    any out-of-pocket expenses as a result of defendants'
    conduct); see also Dornberger v. Metropolitan Life Ins. Co.,
    
                                    21
    
    
    961 F. Supp. 506, 521 (S.D.N.Y. 1997) (stating that section
    1964(c) "requires a showing of some actual, out-of-pocket
    financial loss"); cf. Reiter, 442 U.S. at 340, 99 S.Ct. at
    2331-32 (interpreting "injury to business or property"
    element of Section 4 of the Clayton Act, 15 U.S.C.S 15, and
    stating that consumers who have been "deprived of only
    money, albeit a modest amount," have sustained a
    "property" injury); Rosario v. Livaditis , 963 F.2d 1013, 1021
    (7th Cir. 1992) (where class of beauty school students sued
    beauty schools and the owner under RICO for defendants'
    alleged fraud in inducing plaintiffs to enroll in beauty
    school which provided poor quality instruction,
    substandard equipment and facilities, court stated that
    plaintiffs' RICO injury was manifested by their
    governmental student loans for which they remained
    obligated to repay). Throughout this opinion, we will refer to
    this showing as the "damage element" or the"financial loss"
    requirement of appellants' RICO cause of action. See Oscar,
    965 F.2d at 785 n.1 (stating that "actual injury" means
    "financial loss"); Berg, 915 F.2d at 464 (noting that
    "[a]bsent damages, a RICO claim cannot be sustained").
    
    Stated in its most general form, appellants' argument
    with respect to the damage element of their RICO claims is
    that they have standing under RICO because they paid too
    much in their premium dollars for the health insurance
    they received from Aetna.10 While we will describe the
    _________________________________________________________________
    
    10. At oral argument, appellants' counsel confirmed that appellants are
    claiming that their economic injury is that they paid too much for the
    health insurance they received:
    
           THE COURT: [T]he question is this . . . what would [be] the damages
           that you would propose to show here[.] [W]ould you say that
           [appellants] paid too much for what they got?
    
           [APPELLANTS' COUNSEL]: Yes. We are saying that they paid too
           much for what they got.
    
           THE COURT: And then you would have a jury then, I gather, say
           that the premium, instead of being, and I'm only taking a number,
           $150 per month for each person enrolled, and I know there are
           different levels and all that, should be $130, something like that.
    
           [APPELLANTS' COUNSEL]: Yes.
    
    Tr. of Oral Arg. at 9-10; see also Tr. of Oral Arg. at 21 ("[T]hat is our
    loss. They paid too much, which states a RICO claim, an injury to
    property.").
    
                                    22
    
    
    specific contours of appellants' "overpayment" argument in
    greater detail in our discussion that follows, in a nutshell,
    they claim that their financial loss is demonstrated by
    reference to a rather straightforward damages concept,
    which, they claim, applies squarely to the facts of this case.
    In the interest of clarity, we will refer to appellants'
    argument in this regard as their "RICO injury theory."
    Specifically, they claim that each member of the nationwide
    class paid too much in premiums for an "inferior" health
    care product, i.e., the inferior health insurance they
    received from Aetna through its HMO plan.11
    
    The question presented in this appeal therefore is
    whether the facts as pleaded in the complaint are sufficient
    to support appellants' assertion that they have suffered a
    _________________________________________________________________
    
    11. Appellants utilize the phrase "inferior" throughout their brief to
    describe the health insurance they received from Aetna, see, e.g., br. at
    18, 26, 28, but at oral argument, they characterized the insurance
    simply as "different" from that which was represented to them. See Tr.
    of Oral Arg. at 19 ("They didn't get the product that was represented.").
    While we are not certain whether the different description was
    intentional, we point out that if the health insurance simply was
    different than that which was promised to appellants, there would be no
    factual basis for an argument that they overpaid, inasmuch as a
    "different" but equally good health insurance package would have an
    equivalent economic value. According to appellants, their loss stems
    from the fact that they paid too much in premiums for health insurance
    of lesser value. See Tr. of Oral Arg. at 31 ("And the fraud is that this is
    not what [Aetna] give[s]. Instead, [Aetna] give[s] you a policy, an HMO
    product which is of a lesser value, because its systems--its systemic
    practices, in fact, give you less. Its totally inconsistent with their
    representations."). Obviously, then, Aetna's health insurance could not
    be characterized as "worth less" in monetary value unless it was inferior
    in some respect to that for which they contracted.
    
    Accordingly, we must analyze appellants' RICO injury theory as
    premised on the notion that Aetna's health insurance"product" is
    inferior to that which it promised to deliver. It is inferior, according to
    appellants, because of the existence of the policies and practices outlined
    in the complaint. See id.; see also id.  at 3-4 ("The fact of injury is
    demonstrated by the vast disparity between the economic value of the
    premium HMO product that Aetna represented" and that which
    appellants received, as evidenced by their "allegations which support
    undisclosed systemic practices which directly contrast those promises").
    
                                    23
    
    
    present injury to property, which, according to them, takes
    the form of a financial loss stemming from their
    overpayment for their membership in Aetna's HMO plan. To
    resolve this issue, we must examine the allegations in the
    complaint and any reasonable inferences that may be
    drawn from those allegations, and consider their legal
    significance in view of appellants' injury theory proffered in
    support of the damage element of their RICO claim. 12
    
    As previously mentioned, the district court dismissed
    appellants' RICO claims because it determined that their
    complaint failed to plead sufficient facts to support their
    assertion that they paid too much for the health insurance
    they received through Aetna's HMO plan. The court pointed
    _________________________________________________________________
    
    12. Preliminarily, we note that while this case involves a motion to
    dismiss under Rule 12(b)(6), the Supreme Court recently confirmed that
    we may use appellants' brief "to clarify allegations in the complaint
    whose meaning is unclear." See Pegram, ___ U.S. ___, 120 S.Ct. at 2155
    n.10 (citing, inter alia, Southern Cross Overseas Agencies, Inc. v. Wah
    Kwong Shipping Group Ltd., 181 F.3d 410, 428 n.8 (3d Cir. 1999)). It
    seems equally clear that we may consider statements made by counsel
    at oral argument for that same purpose. See Alicke v. MCI
    Communications Corp., 111 F.3d 909, 911 (D.C. Cir. 1997) ("At oral
    argument counsel for Alicke clarified that, notwithstanding the reference
    to advertising in the complaint, her allegations are directed only to the
    representations contained in MCI's bills.") (cited in Pegram, ___ U.S. ___,
    120 S.Ct. at 2155 n.10).
    
    Moreover, while our standard of review requires us to accept as true
    all factual allegations in the complaint, "we need not accept as true
    `unsupported conclusions and unwarranted inferences.' " West Penn
    Power Co., 147 F.3d at 263 n.13 (quoting Schuylkill Energy Resources,
    Inc. v. Pennsylvania Power & Light Co., 113 F.3d 405, 417 (3d Cir.
    1997)). "[C]ourts have an obligation in matters before them to view the
    complaint as a whole and to base rulings not upon the presence of mere
    words but, rather, upon the presence of a factual situation which is or
    is not justiciable. We do draw on the allegations of the complaint, but in
    a realistic, rather than a slavish, manner." Id. at 263. Also, inasmuch as
    appellants' RICO claims were based upon alleged misrepresentations set
    forth in appellees' marketing, advertising and membership materials
    disseminated to prospective HMO plan enrollees, and provisions in
    Aetna's provider agreements, we may examine and consider those
    materials in resolving this appeal. See In re Burlington Coat Factory Sec.
    Litig., 114 F.3d at 1426.
    
                                    24
    
    
    out specifically that appellants' complaint did not allege
    that they suffered personal injuries, were denied necessary
    benefits, or received inferior care. It further relied on that
    portion of the complaint which stated that "this action does
    not seek to remedy claims of personal injury, contract,
    denial of benefits, medical malpractice and/or wrongful
    death against defendants." JA-25. The court believed that
    inasmuch as the complaint essentially admitted that
    appellants suffered no adverse medical consequences which
    have the potential to decrease the value of their health
    insurance and to cause them to have paid too much in
    premium dollars, appellants' health insurance logically
    could not be "worth less" than what they paid for it.
    
    On appeal, appellees continue to press the argument that
    appellants cannot demonstrate a RICO injury to property in
    the context of this case absent specific allegations that they
    have suffered medical injuries, a denial of necessary
    benefits, reduction of benefits, or inferior care from
    participating physicians as a result of the allegedly
    improper policies and practices challenged in the
    complaint. They state that "plaintiffs do not  claim, and in
    fact, have expressly disclaimed, any injury due to the denial
    of benefits, reduction of benefits, inferior care, malpractice,
    negligence and breach of contract." Br. at 14. Appellees
    characterize appellants' allegations of injury in the following
    manner: "Essentially, plaintiffs contend that the mere
    possibility that a physician might be influenced by
    defendants' alleged `incentives' to withhold necessary
    medical care from, or provide inadequate treatment to,
    plaintiffs if plaintiffs were to develop a covered medical
    condition that required treatment in the form of a covered
    medical service is sufficient, in and of itself, to cause a
    concrete and measurable diminution in the value of
    plaintiffs' HMO memberships from inception." Id. They
    claim that this theory of injury is fundamentallyflawed--
    "as a matter of law and of common sense"--because the
    value of appellants' HMO memberships cannot be
    diminished unless and until appellees' alleged undisclosed
    policies actually cause a denial of medical care or some
    other benefit to which appellants are entitled. Id.
    
    According to appellants, despite the fact that the
    complaint explains their claims as challenging the"quality
    
                                    25
    
    
    of health care services" Aetna provided to its HMO
    members, JA-25, they need not allege any specific
    instances in which appellants were denied medically
    necessary care, received inferior care, delayed treatment or
    suffered medical injuries as a consequence of Aetna's
    implementation of the policies and practices outlined in the
    complaint in order to demonstrate that each member of the
    nationwide class suffered a concrete financial injury at the
    point at which they enrolled in Aetna's HMO plan. As we
    previously mentioned, we understand appellants' RICO
    injury theory as premised on a damages concept which they
    claim supports their bare allegation that they suffered an
    injury to property sufficient to confer standing under RICO.
    
    In particular, appellants rely on the legal principle that a
    consumer suffers tangible economic injury where the
    circumstances demonstrate that the consumer paid too
    much for an "inferior" product. See br. at 27 ("Where, as
    here, plaintiffs have alleged that they have been
    economically injured by defendants' racketeering activity,
    because they have paid too much for the product
    purchased, they have standing under RICO."). Appellants
    apply this principle to the facts in this case by arguing that
    the very existence of the policies and practices outlined in
    the complaint demonstrates that appellants have been
    damaged, i.e., suffered a concrete financial loss, in the
    sense that the health insurance they received from Aetna is
    "inferior" to, and less valuable than, the insurance that
    Aetna promised to provide to its prospective enrollees.
    Appellants thus posit that because the policies and
    practices outlined in the complaint render their health
    insurance "inferior" in comparison to that which Aetna
    promised to them through its marketing, advertising and
    membership materials, they have suffered present economic
    harm in the form of overpayment for an "inferior health
    care product." Br. at 27-28.
    
    Put differently, according to appellants' theory, the
    difference in value between the health insurance promised
    and the health insurance actually received, and
    consequently their RICO injury to property, is demonstrated
    by reference to the intrinsic value of health insurance with
    policies geared towards providing quality health care
    
                                    26
    
    
    services, as compared to inferior health insurance with
    policies driven primarily by fiscal and administrative
    concerns. While not stated explicitly, the existence of
    appellants' financial loss under this theory necessarily is
    predicated on the assumption that Aetna's policies, in and
    of themselves, are of such a nature so as to have a direct
    negative impact on the economic value of appellants' health
    insurance, causing them to have overpaid for what they
    actually received. See JA-54 ("The healthcare provided to
    plaintiffs and the Class is not as represented by defendants
    . . . . As such, the substantial differences in the quality of
    healthcare services marketed by defendants, and the
    quality of healthcare services actually provided to plaintiffs
    and the Class, cause membership in the Plan to be worth
    much less than that actually charged by defendants[in
    terms of premium payments]."); see also  br. at 23 ("As a
    result of Aetna's undisclosed systemic policies and
    fraudulent marketing scheme described above, Aetna's
    HMO members have received a health care product the
    intrinsic worth of which is not commensurate with the
    assurances made and the price charged by defendants.");
    Tr. of Oral Arg. at 31 (noting that the HMO product is of
    lesser value because Aetna's practices "give you less").
    
    According to appellants, their financial loss occasioned as
    a result of their purchase of an "inferior health care
    product" is their present RICO injury which is not
    dependent upon individualized proof concerning the level or
    adequacy of the care that each appellant received under
    Aetna's HMO plan. While they point out that their
    complaint states in general terms that the appellees'
    conduct demonstrates that "benefits were reduced," they
    claim nevertheless that in any event, their position is that
    "what the doctor does or does not do is irrelevant."13 Tr. of
    Oral Arg. at 14.
    (Text continued on page 29)
    _________________________________________________________________
    
    13. Appellants assert in their brief that the district court erred in not
    recognizing that their complaint actually stated several times that
    appellees' policies have compromised the quality of benefits that
    appellants have received under Aetna's HMO plan. See br. at 29 n.11
    ("Contrary to the district court's remark, . . . the Complaint is replete
    with allegations that defendants' undisclosed systemic policies and
    practices actually `reduced the quality' of benefits received."). But
    
                                    27
    
    
    according to appellants, the district court's purported error in that
    regard was harmless, inasmuch as they explain that their allegations to
    that effect are "not essential to the fraud claim asserted here." Id.
    
    At oral argument, counsel for appellants further clarified that,
    notwithstanding the general references in the complaint to the reduced
    quality of care that Aetna's HMO members have received as a result of
    Aetna's policies and practices, it is their unequivocal position that those
    allegations are not essential to their RICO claim, given the type of
    economic harm they claim:
    
           THE COURT: Is there any allegation in the complaint that anyone
           received inferior care, anything other than high quality care? Is
           there any allegation in the Complaint that the physician made
           medical decisions he or she would not have made but for Aetna's
           policies.
    
           [APPELLANTS' COUNSEL]: No. There is no such allegation. There is
           an allegation that benefits were reduced. But I do not believe or we
           do not--our position is that what the doctor does or doesn't do is
           irrelevant. . .
    
           THE COURT: Doesn't that have something to do with quality?
    
           [APPELLANTS' COUNSEL]: It doesn't in terms of what Aetna has
           represented. And, if I may, the District Court I think had a
           misunderstanding of the way the HMOs operate. And this Court's
           decision in the Bauman case illustrates this point. In Bauman, this
           Court noted that HMOs play different roles. A role as a plan
           administrator, which is what I believe the District Court was
           focusing on, under which it makes benefit determinations and its
           conduct is subject to ERISA. But a separate role, the role that's at
           issue here, as a provider of medical services under which it arranges
           and provides for medical treatment.
    
            Aetna represented that it was going to increase access to this
           quality of care. And it is this conduct that the Bauman court, this
           Court, recognized is subject to the prevailing standard of care.
    
    Tr. of Oral Arg. at 13-15. From this colloquy, we understand appellants
    as disclaiming reliance on their ambiguous assertions in the complaint
    that appellees' policies actually have reduced the quality of benefits that
    appellants and members of the purported class received under Aetna's
    plan. Of course, as we previously mentioned, see supra note 12, we will
    evaluate the sufficiency of the complaint's allegations and the legal
    theories articulated in support thereof in accordance with appellants'
    
                                    28
    
    
    For the reasons that follow, we reject appellants' theory
    that their complaint states valid RICO claims based on the
    financial losses they purportedly sustained by enrolling in
    Aetna's "inferior" HMO plan in the absence of allegations to
    the effect that each appellant suffered negative medical
    consequences resulting from Aetna's enactment of the
    policies and practices at issue. Stated another way, in the
    context of this case, we hold that appellants cannot
    establish that they suffered a tangible economic harm
    compensable under RICO unless they allege that health
    care they received under Aetna's plan actually was
    compromised or diminished as a result of Aetna's
    management decisions challenged in the complaint. It
    seems clear to us that unless appellants claim that Aetna
    failed to provide sufficient health insurance coverage to the
    members of their HMO plan in the sense that such
    individuals were denied medically necessary benefits,
    received inadequate, inferior or delayed medical treatment,
    or even worse, suffered personal injuries as a result of
    Aetna's systemic policies and practices, there is no factual
    basis for appellants' conclusory allegation that they have
    been injured in their "property" because the health
    insurance they actually received was inferior and therefore
    "worth less" than what they paid for it. Of course, such
    losses would have to be alleged and proven on an individual
    basis. Inasmuch as we hold that appellants have not
    alleged facts sufficient to establish the fact of damage, i.e.,
    appellants' injury to property stemming from their purchase
    of an "inferior" product, they have no cause of action under
    RICO.
    
    A.
    
    As previously mentioned, at the heart of this appeal is
    appellants' contention that the injury element of their RICO
    _________________________________________________________________
    
    clarifications. See Pegram, ___ U.S. ___, 120 S.Ct. at 2155 n.10 (noting
    that courts may use parties' briefs to clarify allegations in complaint
    whose meaning is unclear); see also Alicke, 111 F.3d at 911 (utilizing
    counsel's statements at oral argument to clarify allegations in complaint
    and nature of plaintiff 's claim).
    
                                    29
    
    
    claims is satisfied in this case by virtue of the difference
    between the "health care product" Aetna represented it
    would provide and that which it actually delivered, and the
    monetary loss that followed as a consequence thereof.
    Based upon their basic description of their purported
    economic harm, we have pinpointed the precise "injury to
    property" that appellants claim to have suffered in this
    case. Importantly, while not explicitly articulated as such,
    we believe that the property injury claimed in this case is
    comprised of two interrelated economic harmsflowing from
    appellants' purchase of an allegedly inferior health care
    product. First, appellants maintain that they have been
    injured in their property in the sense that their tangible
    property, i.e., Aetna's "health care product," has a
    diminished economic value because of Aetna's managerial
    policies. Proceeding from the premise that the value of their
    health care product is less than they believed it to be as a
    result of Aetna's policies, a second aspect of this theory of
    RICO injury is that as a consequence of the diminution in
    value caused by Aetna's conduct, appellants are paying
    monthly premiums that are too high given what they
    actually are receiving, i.e., an "inferior health care product."
    See br. at 23 (noting that Aetna's members received a
    health care product whose "intrinsic worth" is not
    "commensurate with the assurances made and price
    charged.").
    
    Based on our interpretation of the economic harm
    alleged, there is a fundamental problem with appellants'
    injury theory which is fatal to their RICO claims. According
    to appellants, the fact of injury is demonstrated by the
    decrease in the economic value of their property, i.e., their
    health insurance, which occurred as a result of Aetna's
    implementation of its managerial policies and practices, but
    the damages concept of a "diminution in property value"
    does not have a proper application to this case. While
    appellants describe Aetna's health insurance as an"HMO
    product," and claim "injury" to this piece of property by
    virtue of Aetna's restrictive and coercive internal policies
    and practices which allegedly reduce its "intrinsic" value,
    this characterization ignores the nature of the property
    interest at issue--that which is conveyed through
    membership in Aetna's HMO.
    
                                    30
    
    
    Notwithstanding appellants' description of the property
    interests they acquired through their enrollment in Aetna's
    HMO plan, Aetna's HMO is not a tangible property interest,
    like a plot of land or a diamond necklace, as appellants'
    argument necessarily implies. See br. at 30-31 (analogizing
    appellants' claimed injury in this case to plaintiffs' injury
    asserted in Thompson v. Paasche, 950 F.2d 306 (6th Cir.
    1991), reply br. at 4-6 (relying on analogy posited in FTC v.
    Figgie Int'l, Inc., 994 F.2d 595 (9th Cir. 1993)). In the
    context of a case in which the property interest at stake is
    of a tangible nature, it seems logical that an injury to that
    property, and consequently the fact of damage under RICO,
    may be demonstrated by reference to external conditions or
    the occurrence of events which cause the value of the real
    or personal property to be reduced. See Genty v. Resolution
    Trust Corp., 937 F.2d 899, 918 (3d Cir. 1991) (district court
    permitted plaintiffs to recover damages under RICO for
    economic harm occasioned by the loss of the market value
    of their homes as a consequence of defendants' fraud in
    connection with their sale of real property near toxic waste
    landfill); Northeast Women's Ctr., Inc. v. McMonagle, 868
    F.2d 1342, 1349 (3d Cir. 1989) (finding that plaintiff
    satisfied economic injury element of RICO where it
    established that defendants entered plaintiff 's premises
    and destroyed and damaged certain of its medical
    equipment); see also Oscar, 965 F.2d at 790-91 (Kleinfeld,
    J., dissenting) (opining that injury to property element of
    RICO can be satisfied by tenant's claim that defendants'
    tortious conduct caused injuries to her possessory interest
    in leasehold, even if the injury caused no out-of-pocket loss
    to the tenant; dissent argued vigorously that property
    damage would be incurred and measured by virtue of the
    reduction in the value of the tenant's property interest);
    Thompson, 950 F.2d at 313 (finding that the fact of damage
    was demonstrated by the existence of the mineral lease on
    plaintiffs' property, which plaintiffs claimed that defendant
    procured through fraud; the damage stemmed from the fact
    that the lease itself reduced the market value of the
    property).
    
    Here, however, the property at issue is not real or
    personal property; rather, it is a contract for health
    
                                    31
    
    
    insurance.14 Thus, the nature of appellants' property
    interests at stake is their contractual right to receive
    benefits in the form of covered medical services. See
    Pegram, ___ U.S. ___, 120 S.Ct. at 2149 ("The defining
    feature of an HMO is receipt of a fixed fee for each patient
    enrolled under the terms of a contract to provide specified
    health care if needed."); Dukes v. U.S. Healthcare, Inc., 57
    F.3d 350, 358 (3d Cir. 1995) (noting that benefit contracted
    for by enrollees in HMO plan is health care services); see
    also Oscar, 965 F.2d at 789-90 (Kleinfeld, J., dissenting)
    (discussing the nature of the property rights at issue in
    Berg v. First State Ins., 915 F.2d 460, and observing that
    plaintiffs' property interests in their liability insurance
    policies were in the nature of a contract right). When
    viewed from this correct perspective, the economic harm to
    appellants' actual property interests cannot be
    characterized in terms of a "diminution in product value,"
    because the property rights at issue are different from
    interests in real or personal property. See Oscar, 965 F.2d
    at 789-90 (Kleinfeld, J., dissenting) (explaining that the
    kind of property interest at stake determines the type of
    economic injury realized; where property at issue is in the
    nature of real or personal property, a reduction in property
    value is the harm suffered, but where property interest is in
    the nature of a contract right, financial losses occasioned
    by defendant's breach constitute the economic harm
    suffered). And inasmuch as an economic injury to
    _________________________________________________________________
    
    14. Ignoring the distinction between one's interest in real and personal
    property on the one hand, and the type of property interest conveyed
    under a contract, appellants rely substantially on the analysis of the
    Court of Appeals for the Eighth Circuit in Bennett v. Berg, 685 F.2d
    1053, 1058 (8th Cir. 1982), aff 'd on reh'g , 710 F.2d 1361 (8th Cir.
    1983), in which the court found that the plaintiffs' complaint pleaded a
    valid injury to property under RICO based on their allegation that the
    value of their contracts for "life care" was different than they were led to
    expect through the defendants' promises. The outcome in Bennett is of
    little help to appellants because the case did not involve a contract for
    health insurance. Moreover, it did not consider the point we make in the
    text, namely that economic damages based on a decrease in property
    value occur in situations in which the property right at issue is tangible,
    i.e., real or personal property. In any event, to the extent that the result
    in Bennett may be inconsistent with our reasoning, we will not follow it.
    
                                    32
    
    
    appellants' "property" could not stem from a reduction in
    its value given the nature of the property interests at stake,
    appellants' protestations notwithstanding, the fact that
    Aetna implemented allegedly "restrictive and coercive"
    internal policies cannot be considered the determinative
    factor that caused appellants to suffer an economic loss
    compensable under RICO.
    
    Thus, the issue that we must resolve is how appellants
    could establish the fact of damage in this context, i.e., what
    set of factual circumstances must they plead and prove to
    establish a compensable "injury" to their contractual rights
    under Aetna's HMO plan, thus causing them consequential
    monetary loss. In other words, what is the external event or
    condition which would cause appellants to have suffered
    economic harm, and have appellants alleged facts
    demonstrating that the necessary injury-causing event has
    occurred?
    
    Because appellants' property interests in their
    memberships in Aetna's HMO plan take the form of
    contractual rights to receive a certain level (quantity and
    quality) of benefits from Aetna through its participating
    providers, see Pegram, ___ U.S. ___, 120 S.Ct. at 2149, it
    inexorably follows that appellants cannot establish a RICO
    injury to those property rights (which in turn would cause
    financial loss in the form of overpayment for inferior health
    insurance) absent proof that Aetna failed to perform under
    the parties' contractual arrangement. See Oscar , 965 F.2d
    at 789 (Kleinfeld, J., dissenting) (discussing Berg and
    noting that the "nature of the property [in Berg] was a
    contract right. The only damages from injury to that
    property would be on account of loss performance on the
    contract."); Dornberger, 961 F. Supp. at 521-22 (where
    plaintiff paid premiums for life insurance contract and
    claimed that she suffered an injury to property stemming
    from misrepresentations concerning the legality of the life
    insurance contract, availability of guarantee fund protection
    and accessability of local service representatives, court
    found that plaintiff was required to allege facts which
    supported an out-of-pocket loss; court stated that plaintiff
    did not suffer RICO injury equivalent to full amount of
    premiums paid because insurer continued to honor
    
                                    33
    
    
    insurance policies and therefore had not "failed to perform"
    in the sense that it failed to pay out on the policies).
    
    In this factual setting, Aetna's failure to perform (and
    concomitantly appellants' injury to their property) would be
    evidenced by appellants' receipt of inadequate, inferior or
    delayed care, personal injuries resulting therefrom, or
    Aetna's denial of benefits due under the insurance
    arrangement. Absent allegations of such losses, which
    appellants specifically indicate are not involved in this case,
    they cannot establish that they have suffered an injury to
    their property rights encompassed in their HMO
    memberships--i.e., their right to receive necessary medical
    services covered under their plan, and cannot prove a
    consequential financial loss flowing from their property.
    See, e.g., Dornberger, 961 F. Supp. at 521 ("Case law does
    indicate that a plaintiff who is fraudulently induced to enter
    into a transaction does not suffer injury within the meaning
    of S 1964(c) until the defendant fails to perform--that is,
    until it becomes clear that the plaintiff will not get the
    benefit of the bargain.").
    
    Apparently recognizing that the property interests at
    stake are in the nature of contractual rights to health care
    benefits rather than tangible property rights from which
    injury is demonstrated by events causing a diminution in
    value, appellants make a secondary argument that they
    have pleaded injury in this case by referring to Aetna's
    failure to implement policies and practices in accordance
    with its commitment to its members to "raise the quality of
    health care." See br. at 26, 33. Analogizing to the district
    court's analysis in Dornberger, see 961 F. Supp. at 522, see
    reply br. at 8, appellants claim to have suffered economic
    harm, i.e., lost money, by virtue of Aetna's breach of its
    specific promise to implement policies and practices which
    supposedly permitted physicians to provide Aetna's HMO
    enrollees with quality health care.
    
    Invoking the legal principle that payment for services not
    rendered can constitute a valid injury to property under
    RICO, see id. at 523, appellants claim that they suffered
    that exact loss here--they paid a specific part of their
    premium dollars for the benefit of Aetna's promises to
    implement policies designed to foster quality health care
    
                                    34
    
    
    and have been injured in their property by Aetna's"failure
    to perform as promised." Because the "services not
    rendered" aspect of their injury argument only refers to
    Aetna's purported promise to implement policies and
    practices geared towards quality health care, appellants
    contend that "what the doctors do or don't do is irrelevant."
    Tr. of Oral Arg. at 14; see also br. at 25-26 ("Plaintiffs do
    allege . . . that they were denied something Aetna promised
    it would provide its members as an inducement for, and in
    consideration of, the members' enrollment. . . .[P]laintiffs
    and other Class members paid premiums and copayments,
    not just to receive treatment from physicians, but also to
    obtain the benefit of Aetna's services in arranging and
    providing increased quality of care.").
    
    We need not tarry on this argument, as it is premised on
    an erroneous characterization of Aetna's responsibilities to
    its enrollees as defined by the parties' contractual
    arrangement and Aetna's alleged extra-contractual
    promises to deliver "quality health care." Notwithstanding
    appellants' creative description of Aetna's obligations to its
    HMO members, as we have explained they undoubtedly
    sought from Aetna, and Aetna promised to provide its
    members, with a different contractual benefit--namely the
    right to receive covered health care benefits in the form of
    medically necessary supplies, health care services and
    treatment through Aetna's participating providers. See
    Pegram, ___ U.S. ___, 120 S.Ct. at 2149. Indeed, our review
    of the relevant contractual provisions and purported extra-
    contractual promises confirms our understanding of
    Aetna's obligations to its HMO members as their health
    insurer. See, e.g., JA-200, JA-208 (Certificate of Coverage,
    Introduction and "Covered Benefits" sections) (stating that
    "HMO agrees with contract holder to provide coverage for
    benefits" and that covered benefits, i.e. , various services
    and supplies described therein, are those which are deemed
    "medically necessary" by HMO); JA-209 to JA-219 (detailing
    members' specific covered benefits in parts A-R of
    Certificate of Coverage, including, inter alia , "Primary Care
    Physician Benefits," "Diagnostic Services," "Maternity Care,"
    "Inpatient Hospital and Skilled Nursing Facility Benefits,"
    "Emergency Care/Urgent Care Benefits," "Durable Medical
    Equipment Benefits," "Injectable Medications"); see also,
    
                                    35
    
    
    e.g., JA-29 to JA-30 (stating that Aetna represented that
    "its primary commitment, in connection with the health
    care services provided to its HMO members, is to maintain
    and improve the quality of care given to such members");
    JA-30 ("We're committed to Raising the Quality of
    Healthcare in America."); id. (Raising the quality of
    healthcare is our goal.").
    
    Accordingly, regardless of appellants' description of
    Aetna's obligations to its HMO enrollees, contractual or
    otherwise, it is obvious that Aetna's primary commitment to
    its HMO plan members is to provide quality health care
    services through its participating provider network.
    Concomitantly, appellants' contractual benefit is their
    receipt of quality medical services from those sources. We
    reach this conclusion because the provision and receipt of
    covered medical care is at the heart of the parties'
    contractual arrangement and is the driving force behind the
    purchase of health care insurance. See In re U.S.
    Healthcare, Inc., 193 F.3d 151, 162 (3d Cir. 1999) ("[W]hen
    the HMO acts under the ERISA plan as a health care
    provider it arranges and provides medical treatment directly
    or through its hospitals, doctors or nurses."), cert. denied,
    ___ U.S. ___, 120 S.Ct. 2687 (2000); Dukes, 57 F.3d at 358
    (noting that the benefit contracted for under HMO plan is
    health care services).
    
    It necessarily follows from this observation that
    appellants' hypothesis that they suffered financial losses as
    result of Aetna's failure to implement policies designed to
    increase the quality of health care is untenable. Their
    argument rests on the faulty proposition that Aetna's
    implementation of the policies and practices outlined in the
    complaint amounts to a failure to perform a specific
    promise to its members, and misconstrues the nature of
    Aetna's role and its ultimate duty in arranging and
    providing for its members' health care. See Dukes, 57 F.3d
    at 361 (noting that one of the HMO's roles is to arrange for
    the actual medical treatment for plan recipients). Indeed,
    while we do not quarrel with appellants' statement that
    Aetna implemented the managerial policies at issue while
    performing its role in arranging and providing medical
    treatment to its members rather than its role as plan
    
                                    36
    
    
    administrator, see Tr. of Oral Arg. at 14-15, see also In re
    U.S. Healthcare, Inc., 193 F.3d at 162-63, that observation
    does not alter the fact that Aetna's contractual duty to its
    members is to provide medically necessary health care
    benefits in the form of covered services and supplies, i.e.,
    medication, either directly or through contracts with third
    party medical providers. See id. at 162. Accordingly, we
    decline appellants' invitation to define Aetna's duties as
    narrowly as they suggest.15
    
    It is evident to us from the foregoing analysis that given
    the nature of the property interests at stake, appellants'
    RICO injury theory predicated on the concept of a
    "diminution in product value" simply has no application
    here. Rather, in the context of this RICO suit based on
    what appellants have deemed to be "inferior" health
    insurance they received under Aetna's HMO plan, it follows
    from the nature of their property interests in their HMO
    memberships that they would be injured only to the extent
    that they could show that they suffered medical injuries, a
    denial or delay of medically necessary care, or the receipt of
    inferior or inadequate care. We emphasize that any
    personal injuries resulting from Aetna's policies and
    practices would not constitute a compensable RICO injury,
    see Genty, 937 F.2d at 918-19, Oscar, 965 F.2d at 786, but
    instead would serve as the necessary factual predicate for
    _________________________________________________________________
    
    15. Appellants intimate that because their complaint is predicated on
    conduct by Aetna in its role as medical provider rather than its role of
    benefits administrator, it is not necessary that they demonstrate that
    benefits have been denied, reduced or delayed as a consequence of
    Aetna's systemic policies and practices. See Tr. of Oral Arg. at 14-15
    (citing In re U.S. Healthcare, Inc. and suggesting that the district court's
    analysis confused Aetna's two roles). We cannot agree. We do not read
    Dukes v. U.S. Healthcare, Inc., 57 F.3d 350, or In re U.S. Healthcare, Inc.,
    193 F.3d 151, as suggesting that appellants could establish economic
    harm in the circumstances presented here absent proof that Aetna's
    policies and practices actually caused its HMO enrollees' level of health
    care to be diminished or compromised. Indeed, those cases addressed
    the totally separate issue of whether certain state law negligence claims
    brought against U.S. Healthcare, Inc. were subject to complete
    preemption under section 502(a) of ERISA, 29 U.S.C.S 1132(a). See In re
    U.S. Healthcare, Inc., 193 F.3d at 155 (describing issue presented there
    and in Dukes).
    
                                    37
    
    
    their argument that they suffered an injury to their
    property interests--their contractual rights to receive
    insurance coverage and necessary medical services under
    Aetna's HMO plan--which in turn caused them
    consequential financial loss in the form of overpayment for
    the coverage they actually received.
    
    B.
    
    Apart from the analytical problem we described in the
    preceding discussion, we also reject appellants' theory of
    RICO injury resting on the purported diminution in product
    value because, even if we view Aetna's HMO plan as a
    "health care product" as appellants suggest, as a matter of
    simple logic, they obviously cannot show that they actually
    received something "inferior" and "worth less" absent
    individualized allegations concerning the quantity and
    quality of health care benefits Aetna provided under its
    HMO plan. Put differently, assuming arguendo that the
    injury claimed is predicated solely on the allegedfinancial
    loss of premium dollars stemming from appellants'
    purchase of an "inferior health care product," the harm
    alleged, i.e., overpayment, cannot exist absent proof of
    some level of inferior treatment under Aetna's HMO plan.
    
    Appellants cannot reasonably deny that any argument to
    the contrary overlooks the fact that the level of health care
    services that one receives under a health insurance plan
    bears a direct relationship to the "quality" of the product,
    i.e., that person's health insurance, inasmuch as the point
    of procuring health insurance through an HMO plan is to
    secure the benefit of receiving necessary medical treatment.
    See Pegram, ___ U.S. ___, 120 S.Ct. at 2149 (stating that
    HMO is contractually bound to provide promised benefits,
    even if the cost of medically necessary treatment exceeds
    premiums paid); see also Dukes, 57 F.3d at 358 (noting
    that benefit contracted for by enrollees in HMO plan is
    health care services). Given that the concept of"quality"
    health insurance is tied inextricably to the level and
    adequacy of health care that Aetna's HMO members receive
    individually under Aetna's HMO plan, the conclusion that
    appellants' posit, i.e., that they have been harmed
    economically by Aetna's conduct in providing an inferior
    
                                    38
    
    
    "product" in the form of inferior health insurance to its
    HMO enrollees, is provable only by reference to the level
    and adequacy of care that Aetna gave to its HMO members
    under its plan. Cf. Rosario, 963 F.2d 1016-17 (in evaluating
    plaintiffs' RICO fraud claim against beauty schools and
    owner, court cited testimony concerning substandard
    facilities, equipment and teachers which supported
    plaintiffs' assertion that the quality of education they
    received from defendants was poor, thus resulting in
    damages equal to the amount of loan payments incurred for
    educational purposes).
    
    Indeed, we believe that appellants implicitly (albeit not
    intentionally) conceded this point at oral argument when
    we asked counsel to articulate their fraud theory and she
    gave the following response:
    
            Our fraud theory is that Aetna misrepresented the
           type of health insurance coverage that its HMO would
           provide. It is not just based on the quality
           representations they've made, but its also based
           independently upon their promises that doctors make
           medical decisions, and that doctors are compensated
           pursuant to a scheme that enhances quality care, as
           well as the underlying omissions that are not disclosed
           and which clearly render these affirmative statements
           misleading.
    
            And the fraud is that this is not what they give.
           Instead, they give you a policy, an HMO product which
           is of lesser value, because its systems--its systemic
           practices in fact give you less. It is totally inconsistent
           with their representations.
    
    Tr. of Oral Arg. at 30-31 (emphasis added). Counsel's
    statement to the effect that the fraud (and consequently the
    RICO injury) in this case rests on the concept that Aetna's
    policies and practices "gave [appellants'] less" in terms of
    the health insurance coverage it provided through its HMO
    to its members highlights what we perceive as the fatal
    defect in appellants' RICO injury theory as they have
    articulated it. Simply put, appellants cannot demonstrate
    that Aetna's policies "gave [appellants] less" of a "health
    care product" than what Aetna promised to deliver in terms
    
                                    39
    
    
    of the level and quality of health care coverage under its
    HMO plan unless they allege and prove that those systemic
    practices actually negatively affected the health care that
    Aetna provided to its HMO members through its
    participating providers.
    
    In the circumstances, even according to appellants'
    articulated theory of RICO injury predicated on their loss of
    money from their purchase of an "inferior health care
    product," they nevertheless would be required to allege and
    prove that the level of care they received under Aetna's
    HMO plan actually was inferior to that which was
    promised, and therefore "worth less" than they paid for it.
    As we explained previously, any personal injuries that
    Aetna's enrollees might have suffered as a consequence of
    Aetna's management decisions would not constitute the
    RICO injury. Rather, the occurrence of an injury-causing
    event such as, for example, a denial of adequate care or a
    delay in treatment is viewed more appropriately as the
    contingency upon which appellants' economic damages are
    dependent.
    
    In other words, allegations of the foregoing nature are
    necessary to provide the factual basis for appellants'
    otherwise conclusory allegation that they have been injured
    in their "property" because they overpaid for Aetna's inferior
    health care product. Cf. Briehl v. General Motors Corp., 172
    F.3d 623, 628 (8th Cir. 1999) (rejecting plaintiffs' claim that
    their cars were "defective" because ABS system functioned
    in a manner that was counter-intuitive to drivers' natural
    braking tendencies and therefore "worth less" to
    consumers, stating "[w]here, as in this case, a product
    performs satisfactorily and never exhibits an alleged defect,
    no cause of action lies [for fraud, breach of implied
    warranty and violation of state consumer protection laws].
    Since the Plaintiffs have failed to allege any manifest defect
    and their vehicles perform in a satisfactory manner, the
    District Court was correct when it dismissed the Plaintiffs'
    original complaint."). Absent such assertions of diminished
    benefits or care under Aetna's HMO plan, appellants simply
    cannot establish as a factual matter that they received
    anything less than what they bargained for and Aetna
    promised to provide, i.e., a quality health care product, and
    
                                    40
    
    
    consequently cannot claim that they paid too much for the
    health insurance they received.
    
    C.
    
    When we analyze appellants' argument as to why they
    need not plead and prove allegations concerning the level of
    care they received to establish the fact of damage, i.e., their
    RICO "injury to property," it becomes evident why their
    position is fundamentally flawed. Given the total absence of
    any particularized allegations to the effect that the medical
    care appellants received pursuant to Aetna's HMO plan was
    compromised or diminished as a consequence of Aetna's
    internal policies and practices, the fact of damage,
    according to appellants' theory of financial injury, obviously
    is predicated on the concept that the mere possibility that
    a physician might be influenced by Aetna's policies to
    provide substandard medical care to Aetna's enrollees as a
    class demonstrates that the health care insurance they
    actually received is inferior or "worth less" than the amount
    appellants expended in premium payments. As the district
    court described it, appellants' claim of out-of-pocket losses
    as articulated rests on "a vague allegation that quality of
    care may suffer in the future. . . ." Maio , 1999 WL 800315,
    at *2.
    
    We agree with the district court's finding that this
    articulated theory of financial injury is insufficient to confer
    standing on appellants under RICO because it is premised
    solely on their conclusion that the economic value of the
    health insurance they purchased is reduced only because
    of the possibility that the quality of care administered
    under Aetna's health plan will suffer in some undefined
    way at some later point in the future. We understand
    appellants' theory in this regard to be as follows: the fact
    that the policies and practices described in the complaint
    exist make it a near certainty that they will receive
    diminished or compromised health care eventually, which
    in turn demonstrates that they have suffered a present
    economic loss in the form of overpayment for inferior health
    insurance.
    
    But what appellants fail to realize is that the present
    economic harm they allege to have suffered necessarily is
    
                                    41
    
    
    contingent upon the impact of events in the future which
    have not yet occurred. After all, as we previously pointed
    out, appellants pleaded that they are not seeking to recover
    for personal injury, denial of benefits or wrongful death
    already suffered. Moreover, appellants have confirmed that
    they do not claim that the quality of their health care was
    inadequate, and are not relying on their general averments
    that "benefits were reduced." In other words, according to
    appellants, the "inferior" nature of the health insurance,
    and consequently their financial loss, stems only from the
    high probability that given the nature of the policies and
    practices Aetna has implemented, they will receive
    something less than high quality health care when they
    need it, which in turn demonstrates that the health
    insurance is "inferior."
    
    Inasmuch as this articulated theory of RICO injury is
    predicated exclusively on the possibility that future events
    might occur, rather than on the actual occurrence of those
    events and their present effect on the value of the health
    insurance appellants received, we agree with appellees that
    appellants' theory of present economic loss requires a
    significant degree of factual speculation, and is in that
    sense insufficient to support a cause of action under RICO.
    See Gelt Funding Corp., 27 F.3d at 768 (holding that lender
    suffered no present RICO injury stemming from allegedly
    fraudulently induced loans to borrowers where lender
    claimed out-of-pocket losses on account of outstanding
    undersecured loans prior to the completion of foreclosure
    proceedings on the loans; court rejected the "novel theory
    that [lender] was damaged simply by being undersecured
    when, with respect to those loans which had not yet
    foreclosed, the actual [monetary] damages it will suffer, if
    any," had not been determined); Oscar, 965 F.2d at 787
    (where plaintiff claimed economic harm compensable under
    RICO because she allegedly possessed interest in leasehold
    that she could sublet but appellees' racketeering activity
    had the effect of reducing the rent she could charge, court
    rejected theory of financial injury as "purely speculative";
    court observed that plaintiff 's complaint "never alleged that
    she ha[d] a right to sublet her apartment, and in any event,
    did not allege that she ever sublet the apartment, ever
    attempted to sublet the apartment, or . . . ever wished or
    
                                    42
    
    
    intended" to do so); Dornberger, 961 F. Supp. at 522 (noting
    that plaintiff suffered no financial loss stemming from
    insurer's alleged failure to provide guaranty fund protection
    as promised in plaintiff 's insurance agreement, as "the
    guaranty fund would only become relevant upon
    [defendants'] insolvency, a future event whose occurrence is
    speculative"); see also In re Taxable Municipal Bond Sec.
    Litig., 51 F.3d 518, 523 (5th Cir. 1995) (holding that
    plaintiffs lacked standing under RICO because his damages
    claim "would have required extensive speculation and
    would not simply entail a calculation of present, actual
    damages"); Steele, 36 F.3d at 70-71 (noting that a showing
    of RICO injury requires proof of concrete financial loss); cf.
    Briehl, 172 F.3d at 626, 628-29 (where plaintiffs claimed
    economic injury in the form of a reduction in the resale
    value of cars with anti-lock break systems which allegedly
    performed "in a manner completely counter-intuitive to how
    an average driver is conditioned to respond when a hard
    braking maneuver is attempted," court rejected damages
    theory as predicated on economic harm (and a measure of
    damages) that was "too speculative to allow this case to go
    forward;" court noted that plaintiffs had not alleged that
    their ABS brakes malfunctioned or failed, had not alleged
    that they attempted to resell their vehicles, and had sought
    to set their damages as the difference between a vehicle
    with an ABS system that they expected and the system that
    actually is installed in each of their vehicles).
    
    Overall, we are satisfied that if we were to permit
    appellants to proceed with their RICO claims based on
    allegations of monetary loss proved solely by reference to
    what they consider to be the existence of coercive internal
    policies and practices which inevitably will affect the quality
    of care they will receive in the future, we would be
    expanding the concept of RICO injury beyond the
    boundaries of reason. See DeMauro, 115 F.3d at 97 (noting
    that injury to property "is not an infinitely elastic concept").
    Appellants posit that they have lost money because their
    health insurance is inferior as a result of Aetna's policies,
    but the only basis for their conclusion is their subjective
    determination that the policies and practices are so
    inherently unsound that they inevitably will serve as the
    impetus for physicians to provide substandard health care
    
                                    43
    
    
    to their patients at the point at which the enrollees actually
    seek treatment.
    
    If there were any doubt concerning the result we reach,
    which there is not, with respect to the message underlying
    appellants' damages theory, it surely would vanish when
    considered against the backdrop of the Supreme Court's
    recent decision in Pegram v. Herdrich, ___ U.S. ___, 120
    S.Ct. 2143. Given our analysis, it is evident that in the
    absence of allegations that the quantity or quality of
    benefits have been diminished, the only theoretical basis for
    appellants' claim that they received an "inferior health care
    product" is their subjective belief that Aetna's policies and
    practices are so unfavorable to enrollees that their very
    existence in Aetna's HMO scheme demonstrates that they
    overpaid for the coverage they received. Indeed, the concept
    underlying appellants' injury theory is unmistakable--the
    very structure of Aetna's HMO plan is poor in the sense
    that its policies and practices inevitably will result in
    physicians providing inadequate health care to Aetna's
    HMO enrollees, which in turn means that appellants are
    paying too much for inferior health care benefits.
    
    Put differently, we believe that the not-so hidden message
    underlying appellants' RICO claims (and more specifically
    their injury theory) is as follows: while these policies might
    be good for Aetna's business (because that they promote
    increased profits and induce physicians to ration care), they
    certainly are not beneficial to Aetna's HMO members
    because they are medically unsound in that they restrict a
    physician's ability to make independent medical judgments
    and encourage physicians to withhold otherwise
    appropriate health care so as to increase Aetna's"bottom
    line" profits.16 See generally Pegram, ___ U.S. ___, 120 S.Ct.
    
    (Text continued on page 46)
    _________________________________________________________________
    
    16. We only need cite a few examples from the complaint to demonstrate
    what we perceive to be at the core of appellants' RICO claims--their
    ultimate dissatisfaction with the policies and practices outlined in the
    complaint:
    
           68. As a result of these and other systemic practices, defendants
           have significantly interfered with the physician's medical decision-
           making process and have substantially reduced the quality of care
           appellants and the class members receive.
    
                                    44
    
    
           69. In fact, Aetna's practices have come under considerable
           scrutiny from physicians, including the American Medical
           Association ("AMA"), who have criticized the terms of the provider
           agreements as reducing the overall quality and amount of
           healthcare services provided to HMO members and restricting the
           physician's ability to make independent medical decisions regarding
           a patient's healthcare.
    
              . . . .
    
           75. The AMA also specifically identified the following clauses in the
           provider agreements which restrict a physician's ability to practice
           medicine and reduce the quality [of] health care provided to plan
           members:
    
             . . . .
    
           - Interference with medical decision-making, defining covered
           services in terms of medical necessity and giving Aetna-USHC the
           final authority to supersede a physician's determination
           regarding the necessity of medical care; defining medical
           necessity by focusing minimally on clinical medicine and instead
           . . . on cost and convenience to the plan, leaving out any role for
           the treating physician to determine medical necessity.
    
    JA-40 to JA-43. Indeed, the complaint also documents in several
    paragraphs various AMA press releases which criticize, among other
    things, the nature of Aetna's provider contracts andfinancial incentives.
    See, e.g., JA-41 (quoting AMA press release stating that "[w]e believe
    these contracts clearly are not in the patient's best interest. . . . These
    provisions completely blur the line between services that are medically
    necessary and services that the plan simply does not want to cover.")
    (alteration in original); JA-43 (quoting AMA press release stating "[w]e
    have received numerous complaints from physicians around the country
    both about the non-negotiability of [Aetna's] contracts and about
    provisions that potentially undermine the patient-physician
    relationship."); JA-47 ("Aetna's most recent contract embarrassment
    came last month, when four Aetna-owned HMOs were among six
    managed care plans sued by the Texas Attorney General for contract
    provisions that allegedly amounted to illegal payoffs to doctors to limit
    patient care and penalties to those who did not.") (alteration in original);
    JA-48 (quoting statement from AMA which pointed out that "for the past
    year, the AMA has attempted to convince Aetna to ease harmful
    practices that are not in the best interests of patient care and adopt
    practices that will restore trust on the part of patients and physicians").
    
                                    45
    
    
    at 2149 (discussing financial structure of HMOs and the
    fact that profits are tied to physicians' rationing care);
    Herdrich v. Pegram, 154 F.3d 362, 375-78 (7th Cir. 1998)
    (citing and discussing views of various critics of HMOs),
    rev'd, ___ U.S. ___, 120 S.Ct. 2143 (2000); Clark C.
    Havighurst, Vicarious Liability: Relocating Responsibility for
    the Quality of Medical Care, 26 Am. J. L. & Med. 7 (2000)
    (opening article with observation that "[m]anaged health
    care has recently generated a great deal of distrust, even
    anger, in the public mind"); Edith M. Kallas et al., Class
    Actions in the Heathcare Context, SE 34 ALI-ABA 505, 508
    (Oct. 1999) (noting generally that there are "many ways in
    which the structure of the healthcare industry today is
    particularly apt to cause harm to classes of similarly
    situated individuals"). Thus, we think it fair to characterize
    appellants' injury theory as bottomed on the notion that
    Aetna's policies challenged in the complaint render its HMO
    structure "bad" in comparison to the other types of health
    care insurance available in the marketplace.17
    
    The force of this position, we believe, has been
    undermined significantly by the Supreme Court's recent
    decision in Pegram in which the Court rejected the
    plaintiff 's attempt to challenge the existing structure of an
    incentive scheme of one particular HMO under the rubric of
    a breach of fiduciary duty claim under ERISA. In Pegram,
    the plaintiff sued her health maintenance organization and
    its related entities (collectively "Carle"), claiming that Carle's
    HMO structure, which rewarded its physician/owners for
    _________________________________________________________________
    
    17. We further point out that appellants' broad statements in the
    complaint to the effect that appellees' policies and practices actually
    "reduced the quality of health care" its members received only serve to
    highlight the point we make in the text. Indeed, appellants' vague
    allegations that the policies and practices in and of themselves
    demonstrate that the level of benefits is reduced confirm that appellants'
    RICO claims, at bottom, are predicated on the notion that Aetna's
    particular HMO structure is legally objectionable. See, e.g., JA-40 ("As a
    result of these and other systemic practices, defendants have
    significantly interfered with the physician's medical decision-making
    process and have substantially reduced the quality of care plaintiffs and
    the Class members receive.").
    
                                    46
    
    
    rationing medical care in the form of a "year-end bonus,"
    entailed an "inherent or anticipatory breach" of its fiduciary
    duty to its participants. See Pegram, 120 S.Ct. at 2153. In
    rejecting the Court of Appeals for the Seventh Circuit's
    attempt to limit its holding to the particular structure of
    Carle's HMO, the Supreme Court recognized that federal
    courts are not in a position to judge the social value of one
    HMO structure over another, because "any legal principle
    purporting to draw a line between good and bad HMOs
    would embody, in effect, a judgment about socially
    acceptable medical risk." Id. at 2150. The Court explained
    the reasons why it believed that any attempt to distinguish
    among various HMO schemes was unwise:
    
           A valid conclusion of this sort would, necessarily, turn
           on facts to which courts would probably not have ready
           access: correlations between malpractice rates and
           various HMO models, similar correlations involving fee-
           for-service models, and so on. And, of course,
           assuming such material could be obtained by courts in
           litigation like this [under ERISA], any standard defining
           the unacceptably risky HMO structure (and consequent
           vulnerability to claims like Herdrich's) would depend
           on a judgment about the appropriate level of
           expenditure for health care in light of the associated
           malpractice risk. But such complicated fact finding and
           such a debatable social judgment are not wisely
           required of courts unless for some reason resort cannot
           be had to the legislative process, with its preferable
           forum for comprehensive investigations and judgments
           of social value, such as optimum treatment levels and
           health care expenditure.
    
    Id. Given these observations, the Court proceeded to its
    substantive analysis of the plaintiff 's ERISA count on the
    assumption that the types of decisions listed in the
    plaintiff 's complaint, what the Court termed"mixed
    eligibility and treatment decisions,"18  could not be subject
    _________________________________________________________________
    
    18. The Court noted that physicians routinely make mixed eligibility and
    treatment decisions in the course of treating patients, and explained the
    concept of a mixed eligibility and treatment decision by providing
    examples:
    
                                    47
    
    
    to a breach of fiduciary claim unless all such decisions by
    all HMOs were subject to the same sort of claims. See id.
    at 2150-51 ("We think, then, that courts are not in a
    position to derive a sound legal principle to differentiate an
    HMO like Carle from other HMOs.").
    
    Ultimately, the Court held that the plaintiff 's complaint
    failed to plead a valid breach of fiduciary duty claim against
    Carle. Specifically, the Court determined that Carle should
    not be treated as an ERISA fiduciary to the extent that it
    makes mixed eligibility and treatment decisions acting
    through its physician/owners. The Court rejected the
    plaintiff 's claim based in large part on the compelling policy
    considerations that supported its result:
    
           Our doubt that Congress intended the category of
           fiduciary administrative functions to encompass the
           mixed determinations at issue here hardens into
           conviction when we consider the consequences that
           would follow from Herdrich's contrary view. . . .[W]e
           need to ask how this fiduciary standard would affect
           HMOs if it applied as Herdrich claims it should be
           applied, not directed against any particular mixed
           decision that injured a patient, but against HMOs that
           make mixed decisions in the course of providing
           medical care for profit. Recovery would be warranted
           simply upon showing that the profit incentive to ration
           care would generally affect mixed decisions, in
           derogation of the fiduciary standard to act solely in the
           interest of the patient without possibility of conflict.
           Although Herdrich is vague about the mechanics of
           relief, the one point that seems clear is that she seeks
    _________________________________________________________________
    
           The kinds of decisions mentioned in Herdrich's ERISA count and
           claimed to be fiduciary in character are just such mixed eligibility
           and treatment decisions: physicians' conclusions about when to use
           diagnostic tests; about seeking consultations or making referrals to
           physicians and facilities other than Carle's; about proper standards
           of care, the experimental character of a proposed course of
           treatment, the reasonableness of a certain treatment, and the
           emergency character of a medical condition.
    
    Pegram, ___ U.S. ___, 120 S.Ct. at 2154-55.
    
                                    48
    
    
           the return of profit from the pockets of [respondent's]
           HMO owners, with the money to be given to the plan
           for the benefit of the participants. . . . Since the
           provision for profit is what makes the HMO a
           proprietary organization, her remedy in effect would be
           nothing less than elimination of the for-profit HMO. . . .
           It is enough to recognize that the Judiciary has no
           warrant to precipitate the upheaval that would follow a
           refusal to dismiss Herdrich's ERISA claim. The fact is
           that for over 27 years the Congress of the United
           States has promoted the formation of HMO practices.
           . . . [T]he Federal Judiciary would be acting contrary to
           the congressional policy of allowing HMO organizations
           if it were to entertain an ERISA fiduciary claim
           portending wholesale attacks on existing HMOs simply
           because of their structure, untethered to claims of
           concrete harm.
    
    Id. at 2156-57.
    
    We read the Court's approach in Pegram as undermining
    the validity of appellants' RICO injury theory predicated on
    the notion that their health insurance was rendered
    "inferior" by Aetna's implementation of its managerial
    policies outlined in the complaint. In particular, given that
    the very concept underlying appellants' economic harm is
    the notion that the structure of Aetna's HMO plan is faulty,
    we cannot ignore the circumstance that appellants' injury
    theory in essence asks us to pass judgment on the legal
    validity of the policies and practices themselves.
    Accordingly, we find particularly compelling that aspect of
    Pegram which articulated clearly the myriad of practical
    problems which undoubtedly arise in a situation in which
    the federal courts are asked to determine the social utility
    of one particular HMO structure as compared to another.
    See id. at 2150. Indeed, we believe that the Court's
    observations in evaluating the validity of the plaintiff 's
    ERISA claim in that case apply with equal force where, as
    here, appellants' theory of economic injury is predicated on
    the notion that the structure of Aetna's HMO plan, with its
    "coercive and restrictive" internal policies and practices,
    renders the health insurance appellants actually received
    from Aetna less valuable than it otherwise would have been
    without those management decisions in place.
    
                                    49
    
    
    The critical point here is that if we were to accept
    appellants' argument that the fact of damage can be
    demonstrated without specific reference to the level or
    quality of care actually provided to them under Aetna's
    HMO plan, we would be making the social and medical
    judgment that the particular structure of Aetna's HMO plan,
    by its very nature, places it in the category of a"bad HMO"
    as opposed to a "good HMO." There is no escaping that
    analytical step because it is the very nature of Aetna's
    HMO's structure which, according to appellants' theory,
    demonstrates that the economic value of their health
    insurance is reduced, that their insurance is inferior, and
    that they paid too much in premium dollars for what they
    actually received. But it seems clear that in view of the
    Supreme Court's reluctance in Pegram to devise a uniform
    standard by which federal courts could distinguish one
    HMO scheme from another in terms of its social utility in
    the context of an ERISA breach of fiduciary duty claim, we
    must decline appellants' invitation to pass judgment on the
    social utility of Aetna's particular HMO structure, albeit in
    the context of evaluating whether appellants have stated an
    injury to property under section 1964(c) of RICO. We
    especially are constrained to reach our result in light of the
    fact that appellants ask us to make such a determination
    without reference to the level or quality of care that Aetna's
    HMO members received while enrolled in its health plan.
    Cf. id. at 2157 ("[T]he Federal Judiciary would be acting
    contrary to the congressional policy of allowing HMO
    organizations if it were to entertain an ERISA fiduciary
    claim portending wholesale attacks on existing HMOs solely
    because of their structure, untethered to claims of concrete
    harm.").
    
    We also point out that appellants' complaint in effect
    asks that the trier of the fact inappropriately act as a state
    regulatory commission and determine the value of Aetna's
    product. After all the essence of appellants' claims is that
    they overpaid for the product delivered. Thus, at a trial of
    this case the trier of the fact would have to determine the
    value of what Aetna provided. We reject the notion that in
    the complex world of rate structures a trier of the fact,
    probably a jury, can make such a determination.
    
                                    50
    
    
    In any event, inasmuch as we read Pegram as suggesting
    that federal courts are ill-equipped to make the kind of
    social judgment that our acceptance of appellants' injury
    theory would require us to make, we remain convinced that
    in order to demonstrate the fact of RICO injury to property
    in the context of this case, appellants are required to
    demonstrate that the benefits they received under Aetna's
    HMO plan were compromised or diminished as a direct
    consequence of the systemic practices alleged in the
    complaint. Appellants therefore must allege and prove, for
    example, that they suffered personal injuries, were denied
    benefits, or received delayed or inadequate treatment
    because of the structure of Aetna's HMO plan. In the
    absence of such allegations, the district court's dismissal
    was appropriate.
    
    D.
    
    Appellants make one additional argument that we will
    address briefly. Notwithstanding that appellants have
    stated unequivocally that they do not allege, nor intend to
    prove in this case that the quality of care they actually
    received pursuant to Aetna's HMO plan was compromised
    or diminished as a result of Aetna's "systemic policies," they
    contend nevertheless that their allegations of economic
    damage are sufficient at this early stage in the proceedings
    to demonstrate that they suffered an injury to property
    sufficient to confer standing upon them under RICO to
    challenge Aetna's allegedly fraudulent misrepresentations
    and omissions. They point out that the Supreme Court has
    held that " `[a]t the pleading stage, general factual
    allegations of injury resulting from defendants' conduct
    may suffice, for on a motion to dismiss we presume that
    general allegations embrace those specific facts that are
    necessary to support the claim.' " See br. at 39 (quoting
    National Organization for Women, Inc. v. Scheidler , 510 U.S.
    249, 256, 114 S.Ct. 798, 803 (1994), quoting in turn Lujan,
    504 U.S. at 561, 112 S.Ct. at 2137). Essentially, they
    appear to claim that our standard of review on a motion to
    dismiss dictates that they should be given the benefit of the
    doubt that they have suffered tangible economic harm.
    
                                    51
    
    
    Appellants' reliance on this principle is misplaced, for
    while at the pleading stage we must accept as true all
    factual allegations in the complaint and give plaintiffs the
    benefit of all reasonable inferences, it is well settled that
    "we need not accept as true unsupported conclusions and
    unwarranted inferences." See West Penn Power Co., 147
    F.3d at 263 n.13. Inasmuch as there are no allegations in
    the complaint to the effect that appellants have received
    inadequate care, suffered medical injuries, or have been
    denied medically necessary care, the fair inference to be
    drawn from the complaint, indeed the only inference that
    could be drawn in view of appellants' arguments before us,
    is that none of those events have occurred. See Angus v.
    Shiley, 989 F.2d 142, 146-47 (3d Cir. 1993) ("The only fact
    that was not explicitly set forth in the complaint on which
    the court relied . . . was that the valve had not failed. Yet
    that is the fair inference to be drawn from the complaint for
    Angus did not plead that the valve had malfunctioned."). In
    the absence of allegations concerning the quality and
    quantity of benefits that each appellant received, and given
    the disclaimers stated in the complaint, appellants' general
    assertion of an "injury to property" amounts to an
    "unwarranted conclusion" that we need not accept as true
    for purposes of evaluating the sufficiency of the complaint.
    
    Moreover, given appellants' concessions in the complaint,
    which were explicated further in their arguments before us,
    we cannot presume from their general allegation of injury
    that appellants can prove "those specific facts" which we
    deem essential to support their claim of injury to their
    property. Obviously we cannot do so where, as here,
    appellants state specifically that the facts concerning the
    quality and quantity of care they received are not germane
    to their RICO claims. Consequently, the procedural rule
    that requires us to "presume specific facts from general
    allegations" does not apply in this situation. Simply put,
    the result we reach is completely consistent with the
    appropriate standard of review on a motion to dismiss the
    complaint and is compelled in view of the facts and the law
    as we have stated it.19
    
    (Text continued on page 54)
    _________________________________________________________________
    
    19. We address one final point. Appellants contend that the district court
    erred in dismissing their RICO claims with prejudice without addressing
    
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    their request for an opportunity to replead their RICO claims to "cure
    any perceived deficiencies." See br. at 61. While appellants did not file an
    amended complaint or a formal motion for leave to amend before the
    district court, they asked for the opportunity to amend their complaint
    at the conclusion of their brief in opposition to appellees' motions to
    dismiss. Appellants assert that the district court abused its discretion in
    not addressing their request, in that it "did not hold that amendment of
    the complaint would be futile. Appellants were never afforded an
    opportunity to amend their complaint, which they possessed as of right
    as they never previously amended prior to dismissal." Id. at 63.
    
    At oral argument, we asked appellants' counsel what additional facts
    or legal theories that they would plead if given the opportunity on
    remand:
    
           THE COURT: . . . What is it you want to replead? What was it you
           would have pleaded that you didn't plead.
    
           APPELLANTS' COUNSEL: Well, I believe that we have pleaded
           sufficiently to withstand a 12(b)(6) motion. But, you know, if, for
           example the Court believes that we need to more fully plead what
           exactly it is that Aetna was promising that it would do [--a]nd,
           again, I believe the Complaint sets this forth--[w]e could do that
           with greater particularity talking about the kind of system they
           didn't put in place as contrasted with the policies and practices they
           did have in place.
    
    Tr. of Oral Arg. at 29-30.
    
    From our colloquy, we understand appellants as requesting leave to
    amend in the event that we affirm the dismissal on the ground of lack
    of factual specificity or some other readily curable defect. However, given
    the facts of this case, the legal theory presented, and appellants'
    unequivocal position that in view of the economic harm alleged, "what
    the doctor does or doesn't do is irrelevant," id. at 14, it would not be
    possible for appellants to amend the complaint to cure the fundamental
    problem with the complaint as it presently reads. Compare Newark
    Branch, N.A.A.C.P. v. Town of Harrison, New Jersey , 907 F.2d 1408,
    1417 (3d Cir. 1990) (affirming district court'sfinding that complaint's
    allegations were inadequate to demonstrate plaintiff 's associational
    standing, but vacating district court's order denying plaintiff 's motion for
    leave to amend because it "believe[d] that the proposed amendment is
    not facially meritless"). Thus, while we are aware, as appellants point
    out, that in Lorenz v. CSX Corp., 1 F.3d 1406, 1413 (3d Cir. 1993)
    (quoting Foman v. Davis, 371 U.S. 178, 182, 83 S.Ct. 227, 230 (1962)),
    
                                    53
    
    
    V. CONCLUSION
    
    Based on the information pleaded in the complaint, we
    hold that appellants have failed to allege the facts
    necessary to support their assertion that they paid too
    much for the health insurance they received from Aetna.
    Specifically, appellants have not alleged, for example, that
    they suffered medical injuries, received inadequate or
    inferior care, or sought but were denied necessary care as
    a consequence of the structure of Aetna's HMO plan, which
    includes the "systemic policies and practices" challenged in
    the complaint. In the circumstances, appellants cannot
    establish that they suffered a cognizable "injury to business
    or property" flowing from appellees' conduct, an essential
    element of a civil action pursuant to section 1964(c) of
    RICO.
    
    For the foregoing reasons, the district court's judgment of
    September 29, 1999, will be affirmed.
    _________________________________________________________________
    
    we observed that " `outright refusal to grant the leave without any
    justifying reason' " amounts to an abuse of the court's discretion granted
    to it by virtue of Rule 15(a), this is not a situation in which appellants
    simply need to allege more specific factual information in order to
    overcome another defense motion to dismiss. Rather, given appellants'
    stated intention not to rely on allegations of individual medical harm
    flowing from Aetna's policies, and the law as we have stated it, plaintiffs
    could not file an amended pleading that would survive dismissal
    pursuant to Rule 12(b)(6). In the circumstances, then, we will not
    disturb the district court's denial of appellants' request for leave to
    amend, as it clearly would be futile to remand this matter to the district
    court for further proceedings. See Dykes v. Southeastern Pa. Transp.
    Auth., 68 F.3d 1564, 1572 n.7 (3d Cir. 1995) ("While plaintiff elected to
    appeal the dismissal of the complaint rather than seek leave to amend
    under Fed. R. Civ. P. 15, this fact alone does not preclude amendment
    of the complaint. . . . This is not a situation, however, where the
    complaint has been dismissed for lack of specificity or some other readily
    curable defect. Given the facts of this case and the law as we have stated
    it, amendment of the complaint will not result in its being found
    sufficient to withstand a renewed motion under Fed. R. Civ. P. 12(b)(6).");
    cf. Foman, 371 U.S. at 182, 83 S.Ct. at 230 (stating that leave should be
    freely given where "the underlying facts or circumstances relied upon by
    the plaintiff may be a proper subject of relief ") (emphasis added).
    
                                    54
    
    
    A True Copy:
    Teste:
    
           Clerk of the United States Court of Appeals
           for the Third Circuit
    
                                    55

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