The following excerpt is from In re 381 Search Warrants Directed to Facebook, Inc., 29 N.Y.3d 231, 55 N.Y.S.3d 696, 78 N.E.3d 141 (N.Y. 2017):
Under that test, the federal courts recognize the right of litigants to bring actions on behalf of third parties, provided the litigant: (a) has suffered an injury in fact sufficient to inspire concrete interest in the outcome of the case; (b) has a close relation to those third parties; and (c) is free of some hindrance obstructing the third parties' ability to protect their own interests (Powers v. Ohio, 499 U.S. 400, 410411, 111 S.Ct. 1364, 113 L.Ed.2d 411 [1991] ).
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