e interests of a private party, and pursue those interests only for the sake of the real party in interest") (emphasis added); New York by Abrams v. Seneci, 817 F.2d 1015, 1017 (2d Cir. 1987) ("[w]here the complaint only seeks to recover money damages for injuries suffered by individuals" the state lac

to recover money damages for injuries suffered by individuals," Seneci, 817 F.2d at 1017 (emphasis added), California v. Frito-Lay, Inc., on which Seneci relies, concludes a state can be "empowered to act" to seek damages on behalf of individuals, but "that authority must come through ... legislation,