At the heart of the controversy surrounding RICO's civil provisions is the award of treble damages and attorneys' fees to the successful plaintiff. The debate rages over whether plaintiffs are abusing the statute to gain generous awards in lawsuits that do not comply with RICO's intent. In Sedima, S.P.R. L. v. Imrex Co., the U.S. Supreme Court held that closer scrutiny of RICO's pattern requirement might check the statute's potential for abuse. Subsequently, lower courts have analyzed the requirement from a number of approaches. The "expansive" approach finds a pattern of racketeering whenever at least two predicate acts are committed. This approach requires only that the acts be related to find a pattern. The "restrictive" approach requires that the acts not only be related but also evidence continuity, which requires that the pattern arose during the course of separate episodes or schemes. Under the "moderate" or "multifaceted" approach, the commission of two predicate acts is not per se sufficient to satisfy the pattern requirement. The courts conduct a flexible inquiry into a number of factors to determine whether a pattern exists. This "moderate" approach is capable of satisfying RICO's legislative goals as set by Congress without subjecting the statute to abuse. 232 footnotes.