This pattern should be enough to make Myriad's actions sufficiently "proximate" to raise standing, according to Plaintiffs. The brief also cites several cases where the Supreme Court and other appellate courts (including the Federal Circuit) have found standing without direct action against individual plaintiffs, including Doe v. Bolton, 410 U.S. 179, 188 (1973); Virginia v. Am. Booksellers Ass'n, Inc., 484 U.S. 383, 393 (1988); Vt. Right to Life Comm., Inc. v. Sorrell, 221 F.3d 376, 382 (2d Cir. 2000); and Biotech. Indus.