Power of Attorney Insufficient to Confer Standing.   Investment advisor that had discretionary authority to make decisions for its clients and power of attorney to bring lawsuits on behalf of clients did not have constitutional standing to bring securities litigation for damage suffered by clients. Unlike assignment of claim, power of attorney did not transfer title or ownership of claim. Advisor, therefore, had no “injury in fact,” which is constitutional prerequisite to filing suit in federal court. W.R. Huff Asset Mgmt. Co., LLC v. Deloitte & Touche, LLP, 549 F.3d 100 (2d Cir. 2008).