t they relied on certain letters and that the letters/communications proximately caused their damages. Id. at 573-574. The Palmas Court, citing to Bivens Gardens Office Bide., Inc. v. Barnett Banks of Fla., Inc., 140 F.3d 898, 906, 908 (11th Cir. 1998), further reasoned that "a party whose injuries result 'merely fr