What is the test for establishing a pattern of racketeering activity?

The requirement that the plaintiff establish a pattern of racketeering activity is intended to prevent the application of RICO to "isolated or sporadic" criminal acts. United States v. Indelicato, 865 F.2d 1370, 1383 (2d Cir. 1989). To establish a pattern, a plaintiff must identify at least two predicate acts and show that (1) the acts are related both to each other (horizontal relatedness) and to the enterprise (vertical relatedness) and (2) the conduct continued over a substantial period of time. See Reich v. Lopez, 858 F.3d 55, 60-61 (2d Cir. 2017).