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In Haroco v. American National Bank & Trust Co. of Chicago, 747 F.2d 384 (7th Cir. 1984), aff'd, 473 U.S. 606, 105 S. Ct. 3291, 87 L. Ed. 2d 437 (1985), the court held that a defendant violates section 1962(d) when he or she enters into an agreement with knowledge that the goal of the conspiracy is the commission of a RICO violation, that is to 'conduct or participate in the affairs of an enterprise through a pattern of racketeering activity.'


There is a clear division among the circuit courts about the scope of the agreement necessary to violate RICO. See