BCS Services, Inc. v. BG Investments, Inc.

Record contained sufficient evidence to support jury’s verdict in favor of plaintiffs in mail fraud, civil RICO and interference with prospective business advantage claims in alleged scheme by defendants to unfairly deprive plaintiffs of opportunity to bid and obtain properties with tax liens at Cook County auctions by packing auction room with bidding agents, where said scheme violated County’s rule permitting only one bidding agent per potential buyer and increased defendants’ odds at obtaining successful bids on said properties. Record showed that County would have barred defendants' use of multiple bidders had it known of defendants’ scheme, and Dist. Ct. properly refused defendants’ proposed jury instruction that defendants’ alleged good faith disagreement about applicable County rule could negate any intent to defraud. Moreover, plaintiffs’ expert could properly estimate profit plaintiffs would have made for all auctions in which plaintiffs participated, based on number of tax liens on which plaintiffs actually bid in one particular auction in order to calculate various “win” percentages for dishonest, as well as honest, bidders.