interpretation, of the "scope of the private remedy created by" Congress, and the "class of persons who [could] maintain a private damages action under" a legislatively conferred cause of action. A statutory cause of action extends only to plaintiffs whose interests "fall within the zone of interests protected by the law invoked," and the "zone of interests" formulation applies to all statutorily created causes of action, as it is a "requirement of general application" and Congress is presumed to "legislat[e] against the background of" it, "which applies unless it is expressly negated." A statutory cause of action is also presumed to be limited to plaintiffs whose injuries are proximately caused by violations of the statute. A plaintiff suing under §1125(a) ordinarily must show that its economic or reputational injury flows directly from the deception wrought by the defendant's advertising; and that occurs when deception of consumers causes them to withhold trade from the plaintiff. Direct application of the zone-of-interests test and the proximate-cause requirement supplies the relevant limits on who may sue under §1125(a). In discussing the scope of proximate cause, Scalia noted: The previous tests adopted by the various Circuit Courts were dismissed as being problematical on several grounds: Impact The Court's ruling was described as being "a tour de force treatment of statutory standing," and being "certain to earn reprinting in casebooks and citations in briefs for decades to come." It was seen to have greater scope than what was directly related to the case at hand: it was noted as being unusual for the current Court to open the door to more lawsuits the Court has rejected a notable body of existing doctrine relating to standing the Court also took the unusual step of rejecting all Circuit Court interpretations on the question through substituting its own take on the matter the new standard does not define standing requirements as narrowly as some circuits did, but by adding the proximate causation test, it may ultimately make it more difficult for plaintiffs to show standing the Court's focus on statutory purposes and their implication for what a statute authorizes, rather than so-called "prudential" considerations, may limit standing and shift the debate over who can sue under a wide variety of federal laws See also Impression Prods., Inc. v. Lexmark Int'l, Inc.: similar ink cartridge case Chamberlain v. Skylink, another copyright case posing similar DMCA questions Sega v. Accolade, a