The Second Circuit "has never held a period of less than two years to constitute a ‘substantial period of time.’ " Cofacredit, S.A. v. Windsor Plumbing Supply Co. , 187 F.3d 229, 242 (2d Cir. 1999) ; see alsoSpool v. World Child Int'l Adoption Agency , 520 F.3d 178, 184 (2d Cir. 2008) (same); One World, LLC v. Onoufriadis , 2021 WL 4452070, at *2 (2d Cir. Sept. 29, 2021) (summary order) (same). Although the two-year time frame is not "a bright-line requirement," the Second Circuit has stated "it will be rare that conduct persisting for a shorter period of time [will] establish[ ] closed-ended continuity, particularly where ... the activities alleged involved only a handful of participants and do not involve a complex, multifaceted conspiracy."
In order to prove her RICO claim, Oyarzun must allege facts to show a “pattern of racketeering activity.” 18 U.S.C. § 1962; One World, LLC v. Onoufriadis, 2021 WL 4452070, at *1 (2d Cir. 2021). This means she must allege two or more federal crimes from the list of crimes set forth in 18 U.S.C. § 1961.