Market Theory Insufficient Under Illinois Consumer Fraud Act: The Illinois Supreme Court held that a plaintiff's market theory of causation does not satisfy the Illinois Consumer Fraud Act's proximate cause requirement in private actions. Plaintiff's complaint failed to allege that he was, in any manner, deceived. Rather, plaintiff's amended class action complaint focused solely on defendant's advertisements, deceptive statements allegedly made in those advertisements, and alleged increased demand as a result of those advertisements. Oliveira v. Amoco Oil Co., No. 89511, 2002 WL 1340895, ___ N.E.2d ___, (Ill. June 20, 2002).