On May 26th, the Second Circuit affirmed a trial court's finding that special purpose entities ("SPEs") created to provide financing for their parent company have standing to sue defendants, who provided that financing. However, the SPEs failed to state a claim against the lenders for breaches of duty and contract because they failed to allege that defendants were the proximate cause of their injury. The SPEs would have borrowed from the lenders, and sustained their losses, even if no breaches had occurred. Food Holdings Ltd. v. Bank of America Corp. (Summary Order).