In Holmes v. Securities Investor Protection Corporation (1992) 503 U.S. 258, 268-269, 112 S. Ct. 1311, 117 L. Ed. 2d 532, the United States Supreme Court observed that the common law concept of proximate cause demanded "some direct relation between the injury asserted and the injurious conduct alleged. Thus, a plaintiff who complained of harm flowing merely from the misfortunes visited upon a third person by the defendant's acts was generally said to stand at too remote a distance to recover." ( Id. at pp. 268-269.)