In People v. Baumgart (1990) 218 Cal.App.3d 1207, the defendant challenged an order to pay restitution as a condition of probation for selling securities without a permit because in his view some of the restitution "represented victims' losses not proximately caused by his criminal conduct, but by the fraudulent scheme of a codefendant." (Id. at pp. 1210-1211.) In rejecting that argument, the Court of Appeal noted, "it is abundantly clear on our record that the defendant's conduct actually caused the losses to the Gomez investors, who invested their money with Gomez as a result of the defendant's solicitation." (Id. at p. 1223.) The court later reiterated that there was "a direct relationship between the victims' losses and the defendant's conduct." (Ibid.) Thus, while the defendant in Baumgart may have been trying to make an argument about proximate causation--based on the premise that his codefendant's fraudulent scheme was an intervening cause that severed any proximate causal link between his own unpermitted actions and the victims' losses--the Court of Appeal addressed that argument only in terms of direct causation.