plaintiff's injury. The doctrine is actually used by judges in a somewhat arbitrary fashion to limit the scope of the defendant's liability to a subset of the total class of potential plaintiffs who may have suffered some harm from the defendant's actions. For example, in the two famous Kinsman Transit cases from the 2nd Circuit (exercising admiralty jurisdiction over a New York incident), it was clear that mooring a boat improperly could lead to the risk of that boat drifting away and crashing into another boat, and that both boats could crash into a bridge, which collapsed and blocked the river, and in turn, the wreckage could flood the land adjacent to the river, as well as prevent any traffic from traversing the river until it had been cleared. But under proximate cause, the property owners adjacent to the river could sue (Kinsman I), but not the owners of the boats or cargoes which could not move until the river was reopened (Kinsman II). Therefore, in the final version of the Restatement (Third), Torts: Liability for Physical and Emotional Harm, published in 2010, the American Law Institute argued that proximate cause should be replaced with scope of liability. Chapter 6 of the Restatement is titled "Scope of Liability (Proximate Cause)." It begins with a special note explaining the institute's decision to reframe the concept in terms of "scope of liability" because it does not involve true causation, and to also include "proximate cause" in the chapter title in parentheses to help judges and lawyers understand the connection between the old and new terminology. The Institute added that it "fervently hopes" the parenthetical will be unnecessary in a future fourth Restatement of Torts. Efficient proximate cause A related doctrine is the insurance law doctrine of efficient proximate cause. Under this rule, in order to determine whether a loss resulted from a cause covered under an insurance policy, a court looks for the predominant cause which sets into motion the chain of events producing the loss, which may not necessarily be the last event that immediately preceded the loss. Many insurers have attempted to contract around efficient proximate cause through the use of "anti-concurrent causation" (ACC) clauses, under which if a covered cause and a noncovered cause join to cause a loss, the loss is not covered. ACC clauses frequently come into play in jurisdictions where property insurance does not normally include