The complaint further alleges that Apple, in order to convert Fintiv's stolen mobile wallet technology and trade secrets into cash, set up a "fence" by forming an association-in-fact enterprise with leading credit card issuing banks, like JP Morgan Chase and Citibank, and payment processing networks, like Visa and Mastercard, for the purpose of enabling and processing the billions of transactions and trillions in payments that Apple Pay users engage in annually. By utilizing Fintiv's stolen mobile wallet technology and trade secrets in Apple Pay, Apple and the other RICO enterprise members earn tens of billions each year servicing the Apple Pay transactions.